The Brand's Burden of Proof

Under the EU’s EmpCo Directive, environmental claims such as “environmentally friendly,” “green,” or “climate-friendly” must be substantiated—specifically for the product they refer to. Many companies see this as little more than a legal compliance issue. This position paper shows why it goes much further: The claim must be clearly communicated on the product, while the evidence belongs in the Digital Product Passport. And as AI systems increasingly compare and recommend products, what matters is what a brand can actually substantiate.

What EmpCo has required since September 27, 2026—with no grandfathering provisions or transition period
Why “sustainable” is no longer a differentiator when everyone uses it
How a general claim becomes a substantiated statement: characteristic, condition, evidence, reference
Why a product’s success depends on five departments—and none of them is marketing
The claim on the packaging, the proof in the Digital Product Passport
What the German Purity Law teaches us about mandatory labeling and brand pride
Why substantiated product knowledge in AI-generated answers is becoming a brand asset
Three steps to get started in your own organization

As of September 27, 2026, brands must prove what they promise.

What to Expect:

Get the discussion paper on the burden of proof for trademarks

Narravero ist die Plattform für den Digitalen Produktpass.

Narravero is the platform for the Digital Product Passport.