Retail is asking differently now: four questions from listing talks

There is no general EU list of accepted sustainability labels. For retailers a different question therefore matters more: is the claim behind the mark clearly defined, independently checked and available as evidence at short notice?

Since 27 September 2026 a sustainability label may only be used towards consumers if it is based on a certification scheme or was established by a public authority. Before using it, the retailer must make sure the scheme meets the statutory minimum requirements for transparency and credibility.

For private labels this concerns the retailer directly. An assurance from the supplier can form part of the documentation, but it does not replace the retailer’s own check. In listing talks, four specific questions therefore come up more and more often.

1. What does the claim refer to?

Does it cover the product, the packaging or only one component? A claim about the whole product can be unlawful if it actually applies to a part only. A typical example is a recycled content claim that holds for the bottle body but not for the closure, the label or the product as a whole.

2. Who carried out the independent check?

A credible certification scheme needs objective monitoring by an independent and technically competent third party. The EmpCo directive names ISO/IEC 17065 as an example of competence for product certification bodies. Where laboratory testing is used, ISO/IEC 17025 is the relevant accreditation framework.

3. Where are the requirements published?

The conditions of a certification scheme must be publicly accessible. The retailer needs to be able to see what is examined, what scope the mark has and how compliance is monitored. A well-known logo on its own does not answer these questions.

4. Can the evidence be produced at short notice?

EmpCo does not provide for official pre-approval of every claim. Companies therefore need to prepare their claim so that the evidence can be produced without a long search when a retailer asks, in a competition law dispute or during an official review.

What retailers need for their own file

In practice the sticking point is often not the check itself but its documentation. What helps is a clear scope, the name of the assessing body, the requirements applied and an unambiguous certificate or licence number. A public register makes quick verification easier still.

Suppliers going into a listing talk should have this information to hand. flustix certificates can be checked by their licence number in the public database. Where an upstream supplier already holds a suitable certification, it is also worth checking whether the evidence can be carried over to your own product through a sub-licence system.