Tilda Eriksson
The regulatory landscape for sustainability claims on packaging has shifted — and it has done so faster than most teams anticipated. The EU's Green Transition Directive, which came into force in late 2024, drew a hard line: vague, unsubstantiated, or misleading environmental claims on packaging are no longer a brand risk. They are a legal one, with penalties reaching up to 4% of global annual turnover.
For packaging managers, that number lands differently than it does for a legal team or a CMO. It translates into a concrete operational problem: how do you systematically review a packaging portfolio — potentially hundreds of SKUs across multiple markets and formats — and do it fast enough to matter?
This guide is designed to help you answer that question. It walks through a structured audit process, the common failure points, and what a remediation project actually involves in practice.
Why "We'll Know It When We See It" Is No Longer Enough
The old approach to sustainability claims was largely intuitive. A claim felt legitimate, it matched what the brand stood for, it had been on pack for years without complaint. That logic no longer holds.
The Green Transition Directive targets specific categories of claims: generic terms like "eco-friendly," "green," "natural," or "sustainable" that are presented without substantiation. It also scrutinises claims based on carbon offsetting, unverified third-party certifications, and forward-looking commitments framed as current achievements.
The problem for packaging managers is that these claims are often deeply embedded — not just on primary packaging, but across cartons, shippers, multipacks, limited editions, and market-specific variants. A claim that appears once in your brand guidelines can replicate itself across a portfolio quietly and at scale.
An audit gives you visibility. Without one, you are essentially hoping that nothing on your packaging falls into the category of "claim that cannot be substantiated" — and hope is not a compliance strategy.
Step 1: Build a Complete SKU Inventory
Before you can audit anything, you need to know what you are auditing. This sounds obvious, but a surprising number of teams discover during this process that their SKU inventory is incomplete, inconsistently maintained, or fragmented across systems.
Start by pulling a master list from your artwork management system, ERP, or wherever your active packaging files live. Cross-reference it against what is actually in market — sometimes artworks are retired in systems but still running through inventory. Include:
- All primary packaging formats and sizes
- Secondary packaging (cartons, shippers, multipacks)
- Market-specific variants, including any localised claim language
- Digital assets that mirror physical packaging (e-commerce imagery, for instance)
Do not assume that because a claim is only on secondary packaging it is lower risk. Regulators look at the full consumer touchpoint.
At Collabra, when we begin a project of this type, one of the first things we do is map the portfolio by substrate, format, and print method. This matters not just for the audit, but for what comes next: if remediation is required, understanding the format landscape determines how complex that work will be.
Step 2: Identify Every Sustainability Claim on Pack
With your inventory in place, the next step is to extract every sustainability claim that appears across the portfolio. This is not a job that can be done by scanning one artwork — it requires systematic, format-by-format review.
What counts as a sustainability claim for these purposes? Broader than you might expect:
- Explicit environmental claims: "eco-friendly," "sustainable," "green," "kind to the planet," and similar terms
- Material claims: "made from recycled materials," "100% recyclable," "FSC certified," "biodegradable"
- Carbon claims: "carbon neutral," "net zero," "carbon offset"
- Lifecycle claims: references to reduced emissions, water usage, or energy in production
- Third-party certifications: any logo or mark from a certification body, including Rainforest Alliance, FSC, EU Ecolabel, and sector-specific schemes
- Forward-looking statements: "on our way to net zero by 2030" when presented alongside current product claims
The last category is one that often surprises teams. A claim does not have to be factually false to be non-compliant — it needs to be substantiated and precise. "We are committed to reducing our carbon footprint" is different from "This product has a reduced carbon footprint," but both can attract scrutiny if presented without context.
Create a claim register: a working document that lists each claim, where it appears (SKU, panel, format), and what substantiation exists. This becomes your primary audit tool.
Step 3: Assess Substantiation for Each Claim
With your claim register in hand, the substantiation assessment can begin. For each claim, the central question is: if a regulator asked us to prove this, what would we show them?
Work through each claim type:
Material and recycling claims require specificity. "Made from recycled materials" needs to state the percentage. "Recyclable" needs to be accurate for the markets where the product is sold — recyclability infrastructure varies significantly across EU member states, and a claim that is true in Germany may be misleading in a market where that packaging stream does not exist.
Certification claims are only valid if the certification is current, the specific product (not just the company) is certified, and the claim is presented in accordance with the certification body's own usage guidelines. This is an area where packaging teams are often surprised to find gaps — the certification is real, but the way it has been presented on pack does not meet the certification body's requirements, or the licence is held by a printer rather than the brand owner, which creates additional coordination requirements.
Carbon and lifecycle claims are the highest-risk category. These require documented, audited data and are subject to the strictest substantiation requirements. If your team does not have access to a verified lifecycle assessment or third-party carbon audit, claims in this category should be treated as high-risk until substantiation can be confirmed.
Generic terms ("eco," "green," "natural") are the simplest to assess because the answer is almost always the same: these terms, used without further qualification, are no longer compliant. The directive specifically names them.
For each claim in your register, assign a risk status: substantiated, partially substantiated, unsubstantiated, or under review. This gives you a clear picture of where action is required.
Step 4: Prioritise by Real-World Impact
Once you have a risk picture, the temptation is to work through the portfolio sequentially. Resist it.
The right prioritisation logic for a compliance remediation project is not alphabetical, not by brand, and not by how easy it is to fix. It is by real-world consequence — specifically, which artworks are closest to their next print run.
An artwork that is going to press in three weeks needs to be resolved in the next two. An artwork that is mid-inventory with six months of stock in market has more runway. Working backwards from material reorder dates and print schedules is the most operationally rational approach, and it ensures that every hour spent on remediation has maximum impact.
This is a principle we applied directly on a recent project for a leading Nordic FMCG company, where 180 SKUs needed to be remediated within a six-week window. Batching by reorder date rather than project logic meant the most time-critical artworks were always at the front of the queue — and no production schedules were disrupted.
Step 5: Plan the Remediation Work
For artworks flagged as non-compliant, remediation falls into a few categories:
Claim removal is the most straightforward in concept, but not in practice. Removing a sustainability claim from a packaging panel leaves a visual gap. In FMCG packaging, every panel is intentionally composed — removing an element without rebalancing the layout produces something that looks incomplete. Each affected artwork needs design attention, not just a deletion.
Claim replacement happens when you are simultaneously removing a non-compliant claim and introducing a new, substantiated one. This requires testing the new element across all formats, substrates, and print methods to ensure it works consistently — a step that is often underestimated in the planning phase.
Claim qualification is used where the underlying claim is defensible but needs more precision. "Recyclable" becomes "Recyclable in most EU markets — check local facilities." This involves both copywriting and design work, since the qualifier typically requires more space than the original claim.
Certification updates may involve coordination with print partners, particularly where the certification licence is held by the printer rather than the brand owner. In these cases, the final decision about how the certification is presented sits with the printer, and any changes need to be agreed jointly. This workstream often takes longer than teams expect, and it requires active facilitation rather than email chains.
Step 6: Build in Quality Control at Scale
At low volumes, quality control is manageable by eye. At scale — which is where most meaningful compliance projects operate — it becomes a significant operational task in its own right.
For each remediated artwork, the question is not just "is the claim removed?" but "does the artwork still look intentional? Is the rebalance correct? Have any other elements shifted? Does the new claim or qualifier appear consistently across all formats?"
A dual-review proofing process — where two people independently compare each proof against the approved artwork — is the minimum standard for projects of this type. Digital overlay comparison tools accelerate this and reduce human error. Even so, at 180 artworks, proofing alone represents a substantial scheduling and resourcing commitment.
Internal communication infrastructure matters here too. When multiple people are working on the same brand simultaneously, inconsistency is the default outcome unless you actively prevent it. Shared component libraries, pinned reference materials, and clear documentation of decisions already made are not administrative overhead — they are what keep a multi-person project coherent.
What to Watch for as Scope Evolves
Compliance projects rarely stay exactly as scoped. Build that expectation into your planning.
In practice, scope tends to expand in a few predictable ways: a replacement claim arrives mid-project and needs to be phased in alongside the remediation; a certification question surfaces that requires printer involvement; a market-specific variant is discovered that was not in the original inventory; legal or regulatory guidance updates while work is underway.
A rigid project plan breaks under these conditions. A structured but adaptive approach — with clear decision-making authority, rapid communication channels, and a team that understands the full portfolio — absorbs them.
This is one of the areas where having an experienced artwork partner makes a material difference. When scope expands, the question is not just "can we do this?" but "can we do this without losing momentum on everything else?" The answer depends on resourcing, relationships, and institutional knowledge of the portfolio — all of which take time to build and cannot be improvised in the middle of a compliance sprint.
The Certification Complexity Worth Addressing Directly
Third-party certifications deserve their own section, because they are the area where packaging teams most often underestimate complexity.
The issue is structural. Many certification bodies — FSC being the most common example in FMCG — issue licences to printers, not brand owners. This means that the printer controls how the certification mark appears on pack. The brand owner can specify what they want, but any change to how the certification is presented requires the printer's agreement.
This has a few implications for compliance:
- You cannot unilaterally update how a certification is presented on packaging, even if you identify a compliance issue. You need your printer's involvement from the outset.
- If you work with multiple print partners, you may need to align several printers on the same approach — and each has their own prepress workflow, schedule, and internal process.
- The certification body itself may have views on how its mark can appear on packaging, which adds a third party to the alignment conversation.
The practical lesson is to bring print partners into the certification conversation early. Decisions made without them are decisions that may need to be remade. And if you have a partner like Collabra involved, having them present in those conversations means decisions get made with the full implementation picture in mind — including edge cases and specialist formats that a printer or brand team might not have visibility on.
A Note on Timelines
There is no universal answer to how long a compliance audit takes. It depends on portfolio size, how well-maintained your artwork files are, how many people you can allocate, and whether your print partners can respond quickly.
What we can say from experience: organisations consistently underestimate both the audit phase and the remediation phase. The audit feels like administrative work until you start finding claims that need investigation. The remediation feels like simple editing until you start opening artworks and realising that every panel needs individual attention.
If your deadline is firm — which it is, if you are working to a regulatory timeline — the right move is to start earlier than you think you need to, and to bring in additional capacity sooner rather than later. Remediation projects that begin with a narrow team and expand under pressure are harder to manage than projects that begin with appropriate resourcing.
Getting Started
The audit process described here is systematic, but it does not have to be sequential. In most large portfolios, you can run the inventory build and the claim extraction in parallel. You can begin prioritisation before substantiation is complete. And you can begin remediation on high-priority, clearly non-compliant artworks while the rest of the audit is still running.
The worst outcome is a portfolio that reaches a print deadline with non-compliant claims still in place — not because the work could not have been done, but because the audit started too late.
If your team does not have the capacity to run this internally at the pace required, the right question is not whether to get help, but how quickly you can engage it.
Collabra specialises in large-scale packaging artwork management, including regulatory compliance projects across complex FMCG portfolios. If you are working through a compliance remediation and want to understand how we approach it, get in touch →
