What a passport field can and cannot prove

The short answer

A passport field proves the record. It proves that a named party stated a named value on a named date, and if the passport is built properly it proves where that statement came from. That is worth a great deal and it is not the same as proving the claim.

A claim adds three things the field does not carry on its own: a scope, a market and a moment. Whether you can say this garment contains fifty per cent recycled cotton depends on which items the evidence covers, which country you are saying it in and whether the document behind it was true of the goods that actually shipped. A field with a value in it answers none of those three.

In the vocabulary of a passport project the distinction has a shorter form. A field is a datum. Substantiation is a different object: the set of documents that would let somebody else arrive at the same value, held by you, before the words go out. A passport carries the datum. Filling every field in a schema produces no substantiation at all, and a project plan that treats the two as one task will run out of road at the point where somebody asks for the folder.

This page does not test your claim. Nothing here certifies a claim, verifies one or validates one. What it offers is the set of questions that decide the answer, an account of which of them people actually fail, and the two or three provisions that decide most cases before the evidence is opened.

Five tests between a value and a substantiation

These are not ranked by importance. They are ranked by how early they can be answered, because four of them can be answered from the document in your hand and the fifth needs somebody to compare the document with the sentence.

The last row is the one that decides cases. It is also the only one that cannot be answered by looking at the evidence alone, because it is a comparison between two objects: the exact words of the claim, and the exact scope of what you hold. Where two documents describe the same attribute and disagree with each other, that is a different problem with its own procedure, and it is set out on when the lab and the supplier disagree.

When the evidence had to exist

None of the five asks when you got the document, and there is a rule about that which most businesses discover late. Under the advertising code that governs marketing communications in the United Kingdom, the documentary evidence has to exist before the claim is distributed. It is a code rather than a statute, and that distinction matters enough to state plainly, but as an operating rule it is the sharpest thing on this page. Evidence assembled after a challenge lands is not late evidence. On the code's own timing it is absent evidence, and the words went out unsupported whatever turns up afterwards.

Currency has a second failure that nothing in your folder will show you. A document can stay valid while the standard it names stops existing. The catalogue entry for the standard on self declared environmental claims records its edition as withdrawn on 24 June 2026 and replaced by a new one, so every claims policy, supplier contract and technical pack still citing the withdrawn edition now cites a document that does not exist. Nothing flagged that, and we did not find a mechanism anywhere that would have. The replacing edition sits behind a purchase and has not been read here, so this page says nothing whatever about what it contains.

The standard the words have to meet

Substantiation has an operative standard and it is worth reading twice, because it is written as a standard about evidence and behaves as a standard about drafting. In the advertising code, an absolute environmental claim must be supported by a high level of substantiation. A comparative claim is treated differently: it can be justified where the product delivers a total environmental benefit over the thing it is compared with and the basis of the comparison is made clear.

Read that as an instruction about evidence and it sends a business off to buy more evidence. Read it as an instruction about drafting and it says something far more useful. The absolute form of a claim sets a bar the qualified form of the same claim does not, so the cheapest move available is nearly always to qualify the sentence rather than to fund the proof.

The register of decisions assembled for this estate holds fifty-nine records. Not one advertiser in it that set out to prove an absolute environmental claim is recorded as having succeeded. That is a description of the set we assembled rather than a description of advertising everywhere, and the section below says exactly how far it has been checked, but the direction it points in is consistent enough to plan around: absolutes are lost on their wording well before they are lost on their evidence.

The specification rule, which is the commercially important one

A generic environmental claim is defined by what is missing rather than by which words were used. A claim counts as generic where the specification of it is not provided in clear and prominent terms on the same medium as the claim. Turn that definition around and it stops being a prohibition and becomes an instruction, because the same words carrying their specification clearly and prominently in the same place are not a generic claim at all.

The commercial difference is the difference between a swing tag that has to be pulped and a swing tag that has to be reprinted with three more words on it. It is also why a link to a landing page does not rescue a generic claim on a label. A different medium is not the same medium, and the specification has to be where the claim is.

Two cautions travel with this. The definition sits in the amended definitions article of the consumer empowerment directive, which this pass did not read verbatim, so it is carried here as an open check rather than as a settled reading. And clear and prominent is a standard rather than a measurement, so nobody can tell you in advance how small the qualifying words may be set.

The certification gateway has three limbs, not two

The list of practices treated as unlawful in themselves catches a sustainability label that is not based on a certification scheme or not established by public authorities. It also catches a generic environmental claim where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. A great many readers stop at that second description having concluded that the choice in front of them is certification or silence. It is not, and the difference is worth money.

Three routes to recognised excellent environmental performance are named. The EU ecolabel. A national or regional type one scheme officially recognised in member states. Or top environmental performance in accordance with other applicable Union law. That third route does not require a certification scheme of any kind, and its existence is the reason the position here is slightly less absolute than the two limb version that circulates in summaries.

The third limb is stated on this page with its read status attached to it, because that is what it has earned. It rests on the directive's amended definitions article, and this pass did not read that article verbatim. The practice descriptions were read at the Official Journal and the point numbering was independently probed; the definitions article was not, and the difference between those two states is not one a reader should have to guess at. So the third limb is carried as an open publication check rather than as a settled reading, and how the estate handles a source it has not reached is set out on how we know.

A certification proves what it certifies and nothing adjacent

Where a scheme does stand behind a label, one sentence prevents most of what goes wrong next. A certification proves what it certifies. It proves nothing adjacent to what it certifies, however reasonable the adjacent thing sounds when somebody says it out loud in a meeting.

The failure cases all have the same shape. A certificate covering a fibre input carries a sentence about a finished garment. A certificate naming a mill carries a sentence about an order that mill did not make. A scheme that certifies a management system carries a sentence about a product. A certificate about restricted chemistry carries a sentence about environmental impact, which was never inside its scope. In each case the document is genuine, the scheme is real and the claim is unsupported anyway, because the sentence reached past the certificate's own subject. What each kind of document establishes before you ask it to support anything is set out on certificates, declarations and test reports.

Evidence fails on scope, and it fails on absence

A review of published decisions was assembled for this estate, and the pattern across it is consistent enough to be worth stating on its own. Evidence was rejected because it addressed a different product, a different life cycle stage or a different question, or because there was none to produce. No regulator in that set was recorded as disputing the methodology of a life cycle assessment.

That is a statement about the set we assembled rather than about enforcement everywhere, and the next section says how far we have checked it. Taken at that strength it still carries a useful consequence. Expensive, competent, genuinely produced evidence loses when the sentence it is attached to reaches further than it does, and the money spent on producing it is spent either way.

So the highest return control in this subject costs nothing but discipline. Compare the exact words of the claim against the exact scope of the evidence you already hold, before anybody is asked to find more evidence. It is unglamorous, it is not a software feature, and on the evidence we have it would have prevented most of what we read.

There is a second failure mode underneath the first and it is quieter. A claim can be made where no evidence was ever produced, by a system that had no field for evidence and no way to record that the field was empty. A blank that carries no reason cannot tell anybody whether the evidence is missing, inapplicable or simply unrecorded. Putting a reason into that blank is among the cheapest improvements a passport project can make.

Why this page names no decision

The register behind the pattern above was assembled from mixed sources and it has not been closed. Twenty-six of its fifty-nine records sit unverified or only partly verified against the primary decision, and one claim drawn from that pool was refuted outright when somebody checked it independently.

A page that cited a decision it had not read, against the decision itself, would be doing exactly the thing it is warning about, one level up. So the examples are held back. When an item has been checked against its own primary decision and carries that decision's reference, it belongs here and it will appear with the reference attached. Until then the pattern stands and the illustrations do not.

Three specific attributions that were circulating in our own research record are not repeated on this estate in any form. An independent audit refuted the first against the public record, found the second internally implausible and could not source the third at all. They are not restated here, not as examples and not with the names removed, because an anonymised version of a refuted claim is still a refuted claim.

The mass balance question, stated and answered

Does a mass balance certificate let you say fifty per cent recycled on this particular item? It is the most common substantiation trap in textiles and it is very hard to find answered in public.

Our answer is that it does not, and the reason is what the document is. A mass balance certificate records a volume relationship across a supply chain: so much certified input went in, so much output may be sold as certified. It is a real thing about a real system, and it is not a statement about the physical contents of the item somebody is holding. The chain of custody model is part of the claim, and a claim that omits which model it rests on is quietly asserting the strongest of them.

Two limits on that answer, both of which we would rather state than smooth over. We have not read the standard that defines the chain of custody models at its own text, so this describes the shape of the distinction rather than quoting anybody's definitions. And the join underneath is lossy in the direction that hurts: evidence arrives at batch or lot granularity, claims are made at item or model granularity, and no schema we have looked at carries the rule for turning one into the other. Where that join sits in a passport is set out on model, batch or item.

Two different tests, enforced by two different bodies

Businesses selling in the European Union and the United Kingdom keep trying to write one sentence that satisfies both. There is no reason to expect that sentence to exist, because the two regimes ask different questions and are enforced by different bodies.

The European limb

A directive places four described practices onto a list of commercial practices treated as unlawful in themselves. Two of them are the provisions set out above: the sustainability label without a qualifying scheme behind it, and the generic environmental claim. Whether a claim is caught turns on the scheme, on the specification and on the wording, so this is a copy test rather than an evidence test.

What that list is, whom it reaches and when it attaches are on what applies today, which is where this estate keeps the applicability analysis. This page does not restate it and carries no date of its own for it.

The United Kingdom limb, which this page deliberately does not restate

The UK route runs through a different statute and a different enforcer. That is very nearly the whole of what this page says about the statute, because it reached us through a research summary rather than at its own text, and restating a legal test from a summary is the failure this page exists to warn about.

One position on the UK side does have a primary source behind it, because it comes from the regulator's own supply chain guidance rather than from the statute. It has two halves and it is only honest in both. Taking all reasonable precautions is not a defence, and an innocent breach is still a breach. And genuine compliance efforts may be treated as a mitigating factor when a penalty is calculated. Quoting the first half on its own makes a compliance programme look worthless, which is not what the guidance says and would be a poor basis for advising anybody. The same guidance also puts the sequence in an order many businesses do not: a retailer is expected to seek evidence ahead of advertising, and a brand is expected to provide assurance and to share the evidence underneath it.

Two things circulating that this page does not carry

Blocked is not withdrawn. A separate and later proposal on substantiating and communicating environmental claims is blocked, and at least one commercial source publishes it as withdrawn. Those are different states. The check that settles it is a negative one at the primary source: the Official Journal notice listing Commission proposals withdrawn in October 2025 does not contain it, and the last formal procedural event recorded on the file was in December 2024. That check sits in our research record rather than in this page's source register, so it is named here rather than cited, and a file that has not been withdrawn is not thereby a file that is progressing.

A judgment this page does not rely on. There is a judgment on the relationship between compliance with sectoral labelling requirements and the general regime on unfair commercial practices. Its text was never read at the court's own database because the primary route was blocked, so nothing written here rests on it in either direction. It is mentioned only so that a reader who has heard of it knows it is not the authority behind anything above. The reading of it that circulates most widely is the inverted one, as though it held that compliance with labelling law is no defence at all, and that is not a proposition this estate publishes.

What it looks like when somebody else fixed the scope

Most claims in this subject are written by the person making them, which is why scope drifts. It is worth looking at one where it does not.

The substances duty owed to a business receiving an article fixes every part of the claim in advance. The threshold is stated, the subject is the named substance, the minimum content of what is provided is stated, and the whole thing is capped at what the supplier actually holds. Nobody in that exchange gets to choose the scope, so the resulting statement is narrow, checkable and boring, which is what a well formed claim looks like.

The lesson transfers to claims nobody has drafted for you, and it is the same lesson the drafting standard and the specification rule both point at. Fix the scope before you write the sentence: which items, which market, which stage, which period. Then say what you fixed it to, in the same place you make the claim. A claim written scope first is harder to write and considerably harder to lose with.

Sources

• Directive (EU) 2024/825 on empowering consumers for the green transition
  Annex I points 2a and 4a; the definitions article as amendedCELEX 32024L0825In forceRelevant provisions reviewed

  The consumer empowerment directive. Two of the amended annex points were read at the Official Journal and the point numbering was independently probed. The amended definitions article, which carries the third limb of the certification gateway and the same medium test for a generic claim, was not read verbatim by this pass. Both propositions resting on it say so in the sentence that uses them and both are recorded here as open checks. Nothing on this page states when the list becomes applicable, because the estate keeps applicability in one place.

  View official source

• Digital Markets, Competition and Consumers Act 2024 (2024 c. 13)
  In forceReached through a secondary reproduction, primary text not read

  Declared so that the page can name the UK route without describing it. The statute reached us through a research summary rather than at its own text, so this page says that the UK test runs through a different instrument and a different enforcer, and stops there. Restating a test from a summary is the failure this page exists to warn about.

  View official source

• Regulator guidance on supply chain evidence and environmental claims
  Regulator guidanceRelevant provisions reviewed

  The one thing on the UK side that this page states with a primary source behind it, and it is stated in both halves. Taking all reasonable precautions is not a defence and an innocent breach is still a breach; genuine compliance efforts may be treated as a mitigating factor when a penalty is calculated. The half quote makes a compliance programme look worthless, which is not what the guidance says, so both halves publish or neither does. The same guidance carries the ordering rule that a retailer is expected to seek evidence ahead of advertising.

• Advertising code provisions on holding documentary evidence before distribution
  Advertising codeRelevant provisions reviewed

  Carried for two provisions about substantiation rather than for the code as a whole: that an absolute environmental claim needs a high level of substantiation while a comparative claim is tested differently, and that the documentary evidence has to exist before the claim is distributed. It is a code rather than a statute, and the sentences that use it say so.

• Assembled register of advertising and consumer protection decisions
  Assembled register, partly verifiedRelevant provisions reviewed

  The basis of the pattern this page publishes and of nothing else. Twenty-six of its fifty-nine records sit unverified or only partly verified against the primary decision, and one claim drawn from that pool was refuted outright. So the set supports a description of itself at that strength. It supports no named decision, no party and no penalty. Three attributions that an independent audit refuted or could not source are not repeated in any form.

• ISO 14021, self-declared environmental claims, edition withdrawn 24 June 2026
  Withdrawn 24 June 2026Official source confirmed, detailed review pending

  Used for one fact and it is a fact about the catalogue rather than about any text: the edition on self declared environmental claims is recorded as withdrawn on 24 June 2026 and replaced. A technical pack citing the withdrawn edition now cites a document that does not exist. The replacing edition is behind a purchase, has not been bought and has not been read, so nothing here describes what it contains.

• REACH Regulation (EC) No 1907/2006, Articles 3(33) and 33
  Art. 33(1)CELEX 02006R1907-20250422In forceRelevant provisions reviewed

  The worked example of a claim whose scope is fixed by the instrument rather than by the writer. Read in full at the consolidated text. It is here because it shows what a claim looks like when somebody else has already decided the threshold, the subject and the minimum content.

  View official source