Greenwashing Claims: Dated Evidence of What Your Site Said (ECGT)

Why green claims became an evidence question

Directive (EU) 2024/825, often called ECGT or EmpCo, has applied since 27 September 2026, with no transition period. In the UK, the CMA has been able to fine traders directly for breaching consumer law since 6 April 2025, up to 10 % of global turnover. In France, the fine for a misleading practice based on an environmental claim can reach 80 % of the spending on the advertising concerned.

Each of these regimes asks the same factual question first: what exactly did the page say, and on which dates? A claim edited in October or removed last week is still judged by the version consumers saw. Under Article 12 of the Unfair Commercial Practices Directive, authorities can also require the trader to provide evidence of the accuracy of its factual claims.

What changed on 27 September 2026

The directive added new practices to the EU blacklist, which are banned in all circumstances, and tightened the rules on misleading actions. In short:

Generic environmental claims such as eco-friendly, green or climate friendly, unless the trader can show recognised excellent environmental performance relevant to the claim.
Sustainability labels that are not based on a certification scheme or established by public authorities.
Claims that a product has a neutral, reduced or positive climate impact because emissions are offset.
Environmental claims about the entire product or business when they concern only one aspect of it.
Future performance claims, such as net zero by 2035, without clear and verifiable commitments in a detailed, realistic implementation plan that an independent expert checks regularly.

Transposition is uneven and enforcement priorities differ, so check the national measure in each market you sell to. In the UK the CMA Green Claims Code, and in the Netherlands the ACM guidelines on sustainability claims, remain the practical reference for how those authorities read a claim. The evidence workflow below is the same everywhere.

Who needs a dated record, and of what

In-house legal and compliance: proof that a claim was corrected or removed by a given date, and of the exact wording that replaced it.
Law firms acting for competitors: a dated series of the rival's claims for an unfair competition action, a regulator complaint or a cease-and-desist letter.
Law firms defending a brand: proof of what the client's page actually said, set against a screenshot of uncertain origin.
Sustainability and marketing agencies: a record of the claims they approved and published for each client.

The common thread is the date. A regulator asks whether the claim was still live after 27 September 2026, a competitor's lawyer asks how long it ran, and a defending lawyer asks what the page said on the day the complaint was filed. An undated screenshot answers none of these questions well, because it shows neither when it was taken nor whether it was edited afterwards, and the other side will say exactly that.

What to capture

Environmental claims rarely sit on one page. Capture each place where the claim reaches consumers:

Product pages, including the claim, any badge or label, and the text behind info icons or tabs.
Sustainability and impact pages, climate pledges and progress reports published as web pages.
Category pages, banners and checkout messages such as carbon neutral delivery.
Ads and social posts that repeat the claim, including video ads.
The documents behind the claim: certificates, life-cycle assessments and offsetting terms linked from the page.

Capture the documents too. A PDF linked from the page can be replaced at the same URL, and the version that existed when the claim was made is the one that matters.

Proving a claim changed, or came down, by a date

If your team is cleaning up claims, a before-and-after record is the most useful thing you can produce. Capture the page before the edit, capture it again once the new wording is live, and keep scheduled checks running for a few weeks so the old wording does not quietly return through a template, a translation or a cached page.

A capture sealed with a qualified eIDAS timestamp proves that the captured data existed at the time in the timestamp and has not changed since. Under Article 41(2) eIDAS that time and that integrity are presumed, and Article 41(3) makes a qualified timestamp recognised in every member state. It does not prove that a claim was true, lawful or substantiated.

Watching a competitor's claims

For a complaint or a claim against a competitor, one capture is weak: the other side will say the page changed long ago. A weekly series, with a manual capture whenever a campaign launches, shows how long the claim ran and in which wording.

Put each product, category and sustainability page under its own monitor.
Switch to a daily schedule during campaigns such as Black Friday or a product launch.
Capture each language and country version separately, because the wording often differs.

Server captures are public by default. Unpublish the proofs in the dashboard if you do not want the competitor to find them before you act.

Building the claim register

Whether you are defending or attacking, the output is the same: a register that a regulator, a judge or opposing counsel can follow.

One row per claim: exact wording, URL, market and language.
The first and last date the claim was captured, with the proof identifiers.
The substantiation relied on, sealed as a file proof with its hash.
What was changed, when, and who decided it.

In our dashboard you can group the proofs of one matter in a case folder and export the whole case as one ZIP with an index CSV, a ready start for that register. Anyone can verify each package offline with the open-source gpa-verify.

Which tool for which step

Three products cover the workflow, and most teams combine them.

Website Monitoring for the series: scheduled daily or weekly checks, each a proof with a qualified eIDAS timestamp, and an e-mail when the page changes. Business 99 EUR per month with 10 monitors, Monitoring 50 at 399 EUR and Monitoring 100 at 599 EUR, all excl. VAT.
Forensic Browser for journeys and video: a product page with its tabs and checkout, a logged-in retailer portal or a video ad, captured as one sealed session, with the linked PDF sealed as a file. Annual licences from 290 EUR excl. VAT.
Assisted Capture when a campaign is live right now: our operator captures the URLs for you, Rush within 60 minutes guaranteed for 249 EUR excl. VAT.

A schedule is not continuous monitoring: a claim that appears and disappears between two checks is not recorded, so choose the interval to fit the risk.

FAQ

Does the ECGT directive apply in the UK?

No. In the UK, environmental claims are assessed under the Digital Markets, Competition and Consumers Act 2024 and the CMA Green Claims Code. The evidence question, what the page said and when, is the same.

Does a qualified timestamp prove our claim was lawful?

No. It proves when the page was captured and that the captured data has not changed since. Whether the claim was lawful depends on its wording, context and substantiation.

How often should a claims page be checked?

Weekly is enough for most pages; daily during campaigns or while a dispute or inquiry is running. Add a manual capture whenever the wording changes.

Can we monitor a competitor's website?

Yes, any public page can be a monitor. Pages behind a login or multi-step journeys are better captured with Forensic Browser or the browser extension.

Can we see a sample before buying?

Yes. Send one public URL with an environmental claim to sales@getproofanchor.com and we capture it as a free sample, so you can inspect the evidence package before choosing a plan.

Sources

For compliance and audit teams

Prove what was published — and when it changed

Scheduled forensic captures of policies, prices, disclosures and competitor claims. Every run is a sealed proof with an eIDAS qualified timestamp, building an unbroken evidence series.

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Related guides

Keep a dated record of every green claim

Put your own and your competitors' claim pages under scheduled monitoring, capture video ads and linked documents in Forensic Browser, or let our operator capture a live campaign now. Every proof carries a qualified eIDAS timestamp.

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Business from 99 EUR/month, Monitoring 50 399 EUR, Monitoring 100 599 EUR, Forensic Browser from 290 EUR/year, Assisted Capture from 49 EUR, all excl. VAT. Not legal advice; no guarantee of how a regulator or court weighs the evidence.

Green claims and greenwashing: dated evidence of what the website said