Custom sustainability claims substantiation file development
Since Directive (EU) 2024/825 was implemented in Book 6 of the Dutch Civil Code, stricter rules apply to environmental claims aimed at consumers. A generic claim such as 'eco-friendly' is only allowed with recognised excellent environmental performance, your own sustainability logo only on the basis of a certification scheme, and a claim that a product is climate neutral thanks to offsetting is prohibited. If a claim is challenged, the burden of proof lies with the trader. Appfront builds the file that records each claim with its scope, evidence, source and validity.
What is software for the substantiation file behind your sustainability claims?
A claim substantiation file records, for each environmental claim, exactly what is being claimed, what it applies to and what proves it. In law, an environmental claim is any non-mandatory message or representation, including a label, brand name or image, that states or suggests that a product, brand or trader is better for the environment. Since the implementation of Directive 2024/825, Article 6:193g of the Dutch Civil Code lists as misleading, among other things: a sustainability label that is not based on a certification scheme, a generic environmental claim without recognised excellent environmental performance, a claim about the whole product when it concerns only one aspect, and a neutral or reduced impact claimed on the basis of greenhouse gas offsetting.
At most companies, that substantiation is scattered. Marketing writes the copy, quality has a supplier's report, the label certificate sits in a folder, and a claim about 2030 rests on a plan nobody updates any more. A claim appears on the packaging, the website and in a campaign, and nobody knows which version is where. When a consumer, a competitor or the ACM (the Dutch Authority for Consumers and Markets) asks for proof, the search begins, while Article 6:193j of the Dutch Civil Code places the burden of proving accuracy and completeness on the trader.
We build custom software because every company makes different claims. A manufacturer claims recycled material, a retailer carries suppliers' sustainability logos, an energy company or travel organiser talks about emissions. Which products and channels you have, which labels you use, where your evidence comes from and who approves a claim determine what the software does. The judgement on whether a claim is allowed stays with you and your lawyer; the software makes sure the evidence and the assessment are kept together.
Per claim
Wording, scope, channel.
With evidence
Source and validity.
Assessed
Against the new rules.
How we build your software for the substantiation file behind your sustainability claims
We start with your claims: which ones you make, on which products and in which channels, which labels and certificates you use, where the evidence currently sits and who decides. Then we build a first version with the register of claims and their evidence, because that is where the overview begins. Your marketing and sustainability teams work with it for a while. The checking of labels and future claims, the alerts for outdated evidence and the integration with your product information follow once that works well. After that, we keep the software up to date as the rules or your claims change.
Products, channels, evidence.
The first version.
Labels, future claims, validity.
Go-live, monitoring, and maintenance when things change.
What software for the substantiation file behind your sustainability claims actually does
The components below appear in almost every substantiation file. Which ones you need depends on your claims and your organisation.
Register
Every claim in one place.
Proof
Report, certificate, calculation.
Compliance check
Against Article 6:193g of the Dutch Civil Code.
Certifications
With a certification scheme.
Future claims
Plan and verification.
Validity
Alert when evidence is out of date.
Who we build software for the substantiation file behind your sustainability claims for
The software is intended for companies that make more than a handful of environmental claims, across multiple channels or on many products. The more claims you make and the more often they change, the more it delivers.
Manufacturers
Claims on products and packaging.
Retailers
Suppliers' logos and claims.
Brand owners
Campaigns and website.
Service providers
Claims about emissions.
Test your idea first: a working prototype in 1 day
With OneDayBuild, we make your idea tangible in a single day for €1,150, so you know whether further development is worth the investment. Decide to go ahead with the full build? Then we deduct the cost in full.
View OneDayBuild →Technology and integrations
This page is about the evidence behind claims made to consumers. For your company's sustainability reporting, see our page on CSRD and ESG reporting software; for your own emissions, our page on carbon accounting; for product data per item, our page on the digital product passport; and for collecting data from suppliers, our page on the supplier portal for sustainability data. You can read about our approach on building software.
Why Appfront for software for the substantiation file behind your sustainability claims?
A claim that stays on the packaging while the report behind it is out of date, your own logo without a certification scheme, or a climate claim based on offsetting can lead to an enforcement request or a lawsuit, and then the burden of proof is on you. That is what we build around: every claim with its evidence, checked against the rules, and a file that is ready when someone asks for it.
Overview
All claims and channels.
Demonstrable
Evidence per claim.
Up to date
Expiry monitored.
Security and privacy in software for the substantiation file behind your sustainability claims
The file contains research reports, calculations and supplier data that are often confidential. Access is set up per role: marketing sees the claims, the sustainability department the evidence, legal the assessments, and only those authorised can approve a claim. Every change and approval is recorded with name and time.
The software runs in a European data centre, with encrypted connections and storage and daily backups. An approved version of a claim, with the evidence as it stood at that moment, cannot be overwritten, so you can later show what you based the claim on when it was made.
Frequently asked questions about software for the substantiation file behind your sustainability claims
Questions that marketing, sustainability and legal departments ask before getting started.
A file that records, for each environmental or sustainability claim, exactly what is being claimed, on which product and in which channel, what proves it, until when that evidence is valid and who approved the claim. It lets you show that a claim is accurate and complete.
Book 6 of the Dutch Civil Code has been amended by the act implementing the directive on better sustainability information for consumers (Implementatiewet richtlijn betere duurzaamheidsinformatie voor consumenten), which transposes Directive (EU) 2024/825. According to the ACM, the new European rules on sustainability claims and labels apply from 27 September 2026. The ACM supervises compliance and has published Guidelines on Sustainability Claims with rules of thumb.
A general claim such as 'environmentally friendly' or 'green', without the same medium making clear what exactly is meant by it. Such a claim is only allowed if you can demonstrate recognised excellent environmental performance, such as the EU Ecolabel or an officially recognised type I ecolabel.
No. Claiming that a product has a neutral, reduced or positive impact thanks to the offsetting of greenhouse gas emissions is on the blacklist in Article 6:193g of the Dutch Civil Code. You can still communicate about your own reductions and about offsetting as a separate activity, provided it is accurate and substantiated.
A claim about future environmental performance requires clear, public and verifiable commitments in a detailed and realistic implementation plan with measurable targets, regularly verified by an independent external expert whose findings are available to consumers. The file keeps track of the plan, the targets and the verifications.
That is a European Commission proposal for further rules on substantiating and verifying claims. The Commission lists the proposal as pending; it is not current law. What applies now is Book 6 of the Dutch Civil Code following the implementation of Directive 2024/825.
For companies with many products, channels or labels, or with claims that rest on measurements and plans. If you make only a few claims that rely on a single certificate, a well-maintained overview with the supporting evidence is often enough.
Is the evidence behind your sustainability claims in order?
Tell us which claims you make, on which products and in which channels, and where the evidence currently sits. We will show you how the software can handle it.