ISO 14021 environmental claims: how to substantiate them

What are ISO 14021 environmental claims, and what changes in the 2026 edition?

ISO 14021 environmental claims are the statements a company makes itself about the environmental qualities of its products: “contains x% recycled material”, “recyclable packaging”, “reduced energy consumption”. Since June 2026 the reference standard is ISO 14021:2026; the 2016 edition and its 2021 amendment are withdrawn.

ISO 14021:2026 — Environmental statements and programmes for products — Self-declared environmental claims (formerly ISO 14021:2016) is the 3rd edition of the standard, published in June 2026 by subcommittee ISO/TC 207/SC 3. According to its iso.org page, read on 11 November 2026, it establishes principles, specifies requirements and gives guidance on self-declared environmental claims about products and on their programmes. It defines a selection of terms commonly used in such claims, with the qualifications for their use, and describes the documentation and methods needed to assess them.

For a manufacturer in Morocco, elsewhere in Africa or in the Middle East selling into Europe, this is the standard behind most of what goes on a pack, a data sheet or a tender response. Two short definitions used below:

• Self-declared environmental claim: a claim the company words and documents itself, with no third-party certification. It is what used to be called “type II environmental labelling”.
• Environmental claim: under Directive (EU) 2024/825, any non-mandatory message (text, picture, symbol, label, brand name, company or product name) that states or implies that a product, brand or trader has a positive or zero impact on the environment, is less damaging than others, or has improved its impact over time.

What the 2016 and 2026 iso.org pages show

What the abstracts do not give you is the exact list of defined terms (recycled content, recyclable, compostable and so on) and the conditions for using them in the 2026 edition. Those are in the text of the standard, which ISO sells in English and French; we do not paraphrase it here. In practice, never reuse a definition from an old catalogue or a supplier data sheet written against the 2016 edition without checking it against the 2026 text first.

The 2016 abstract stated that the standard does not override or change any legally required environmental information, claim or labelling. That remains the right way to read it: a voluntary standard helps you word a claim well, it never allows what the law forbids.

Type I, II and III: how do ISO 14020, 14021, 14024, 14025 and 14063 fit together?

ISO 14020 sets the principles shared by all product environmental statements; three standards cover the tools (ecolabel, self-declared claim, environmental product declaration); ISO 14063 covers the organisation’s environmental communication as a whole.

The 2026 editions renamed the family: “Environmental labels and declarations — Type I / Type II / Type III” became “Environmental statements and programmes for products — Ecolabels / Self-declared environmental claims / Environmental product declarations (EPDs)”. Buyers still talk about types I, II and III, and Directive (EU) 2024/825 still refers to “type I” ecolabelling.

Two notes on editions. ISO 14020:2022 has a draft amendment, ISO 14020:2022/DAmd 1, at stage 40.60 (close of voting) on iso.org on 11 November 2026; no new edition has been announced. ISO 14063:2020 was reviewed and confirmed in 2025.

EPDs deserve their own guide, since they rest on a full LCA and a programme operator. To place LCA, carbon footprint and EPD side by side, see our comparison carbon footprint vs LCA: which ISO standard and our ISO 14067 product carbon footprint guide.

How do you substantiate a self-declared claim under ISO 14021:2026?

With an evidence file, built before the claim is printed or posted, that lets a third party check the claim without having to call you. A claim with no file is a claim to withdraw.

Our method, applied claim by claim and using the copy of the standard you hold:

1. Write down the exact claim: wording, symbol, medium, market, audience (EU consumers or business customers).
2. Fix its object: the whole product, the packaging, one component, one site. The message must never go beyond that object.
3. Check the term: is it defined in ISO 14021:2026, and under what conditions? Is it regulated in the market where you sell?
4. Collect the data: source, period, calculation or test method, boundary, supplier documents.
5. Assess the claim using the method the standard describes for that type of claim, and keep the calculations.
6. Word it: precise, quantified where possible, with the reference year and access to the evidence.
7. Name an owner and a review date: any change of recipe, supplier, process or market reopens the file.

The claims exporters make most often

A typical case: a tray maker in the Tangier region printed “recycled tray” when only the base contained recycled material and the lid was virgin plastic. The claim went beyond its object. Reworded as “tray base made of x% recycled plastic, lid excluded”, backed by a quarterly material balance and the pellet supplier’s certificates, it becomes defensible. The “x” is replaced by the measured value, never by an estimate.

Checklist: the evidence file for a self-declared claim

• The exact wording of the claim, its medium and every market where it appears.
  
• The object of the claim (product, packaging, component, site), written down and consistent with the message.
  
• The reference to the term in ISO 14021:2026, not in the withdrawn 2016 edition.
  
• Source data, period and origin (internal measurement, supplier, laboratory).
  
• The assessment or calculation method, with the calculations kept on file.
  
• A dated baseline for any comparative claim.
  
• A check against the law of the market of sale, cleared by your legal counsel where needed.
  
• The file owner and the next review date.
  
• Your customer’s written approval before printing, for private-label production.
  

Is a claim that meets ISO 14021 allowed in the European Union?

Not automatically. ISO 14021:2026 is a voluntary standard; for EU consumers, what applies since 27 September 2026 are the Member State laws transposing Directive (EU) 2024/825 (Article 4 of the Directive, transposition by 27 March 2026, read on EUR-Lex on 11 November 2026).

The Directive adds several practices to Annex I of Directive 2005/29/EC, the list of commercial practices that are unfair in all circumstances. Here is where they meet the ISO environmental statement standards:

The full list of bans, the rules on future claims (“net zero by 2040”) and the status of the proposed Green Claims Directive are covered in our article on Directive (EU) 2024/825 and environmental claims. Carbon neutrality claims and the ISO 14068:2026 approach are covered in our ISO 14068 carbon neutrality guide.

What if you sell to businesses?

Directive 2005/29/EC covers traders’ practices towards consumers. A supplier selling a material or component to a European manufacturer is not covered as such. But a claim it prints for a brand, or that its customer lifts from its data sheet, often ends up in front of a consumer. That is why we build the evidence file for a B2B claim exactly as we would for a B2C claim: your customer will ask for it before printing.

When should you aim for an ISO 14024 ecolabel instead of a self-declared claim?

When you want a general environmental message for EU consumers, or when your customer requires a certified label. For one precise, measurable attribute, a well-documented self-declared claim is often enough.

ISO 14024:2026 — Environmental statements and programmes for products — Ecolabels (formerly ISO 14024:2018) is the 3rd edition, published in May 2026. According to iso.org, it specifies principles and requirements and gives guidance on ecolabelling programmes and ecolabels: programme development, selection of product categories, product environmental criteria and product function criteria, and the process for assessing and certifying products licensed to use the ecolabel. It also explains how a conforming ecolabel can be told apart from other environmental statements on the market. The 2018 edition was titled “Type I environmental labelling — Principles and procedures”.

A company does not apply ISO 14024: it applies to a programme that does. Questions to ask before choosing one:

• Is the programme the EU Ecolabel, or a type I ecolabel officially recognised in the Member State where you sell? If not, it does not demonstrate the recognised excellent environmental performance required for a generic claim.
• Are criteria published for your product category?
• Who assesses and certifies, under what procedure, and how often is the licence reviewed?
• Does the label cover the product you sell, or only part of the range?
• Do your production data and your suppliers’ data let you demonstrate every criterion?

Here ACG prepares the application file and the evidence; the ecolabel programme assesses and certifies.

How do you organise environmental communication with ISO 14063?

By treating claims as a company process rather than a marketing decision. ISO 14063:2020 gives guidelines, not certifiable requirements, for all environmental communication, internal and external.

ISO 14063:2020 — Environmental management — Environmental communication — Guidelines and examples (formerly ISO 14063:2006) applies, according to iso.org, to any organisation regardless of size, activity or products, whether or not it has an environmental management system. It covers general principles, policy, strategy and communication activities, and can be used with any ISO 14000 standard or on its own. Its page points to ISO 14020, ISO 14021, ISO 14024, ISO 14025 and ISO 14026 for the tools specific to product labels and declarations.

For an exporter, it comes down to four things:

• A single claims register: every message, on every medium and in every market, with its evidence file.
• An approval procedure before anything is printed or posted: quality, marketing, sales, and legal counsel for sensitive cases.
• Consistency across media: a food group whose sustainability report announces a packaging reduction of x% cannot show a different figure on its website. Your answers to customers’ ESG questionnaires (see CSRD, VSME and ESG questionnaires) and your data sheets must tell the same story.
• A link to your management system: if you are ISO 14001 certified, environmental communication and the control of documented information belong there (see our ISO 14001 certification page).

Packaging claims (recycled content, recyclability, reuse) also meet the EU packaging regulation: see PPWR and packaging and our PPWR guide for non-EU exporters.

Which mistakes should you avoid with self-declared environmental claims?

Most mistakes come from claims written before the evidence, or copied from an old document. Five come up again and again in our work with manufacturers and exporters:

1. Citing a withdrawn edition: “compliant with ISO 14021:2016” on a 2027 data sheet. Cite ISO 14021:2026.
2. Presenting a self-declared claim as a label: a company-made pictogram next to a standard-compliant text is still an in-house logo under EU law.
3. Generalising a partial performance: “recyclable” packaging whose lidding film is not.
4. Counting carbon credits in a product claim: banned for EU consumers, whatever the quality of the credits.
5. Letting the file go stale: a change of recycled-material supplier invalidates a percentage printed on thousands of packs.

ACG supports manufacturers in Morocco and across Africa on these topics with 10 in-house consultants and more than 100 qualified external experts; the firm has run 502 projects and trained more than 120,000 people. Our position does not change: evidence first, wording second.