Is a supplier declaration sufficient evidence for a green claim?

No. A supplier declaration is the supplier’s own statement. It does not meet the requirements for a certification scheme, and it does not shift liability. Responsibility for an environmental claim towards consumers stays with whoever makes the claim.

Why this is the most common gap

The typical sequence: the brand owner takes a figure from the supplier’s data sheet, say “30 % recycled content”, and turns it into a claim on the packaging. A technical statement between two companies thereby becomes a commercial practice towards consumers. EmpCo applies to that, and what counts there is not what the supplier assured but what can be substantiated.

If a complaint arrives, the evidence is requested at short notice. Anyone who has to ask the supplier for it at that point does not have it in time.

What a supplier declaration is still good for

It can form part of internal documentation and is one building block of the technical documentation under the PPWR. It is the starting point, not the evidence. A claim towards consumers needs proof that comes from an independent body.

What does carry the claim

Evidence from a certification scheme: published requirements, testing or an audit by an independent body, conformity assessment by a third party, and a result others can verify. At flustix, laboratories accredited to ISO/IEC 17025 carry out the testing, the conformity assessment follows ISO/IEC 17065, and every certificate can be looked up by its licence number in the public database.

One particularity in the supply chain: where the supplier has the material certified, the evidence can be passed on to the customer through the sub-licence system. What then sits behind the figure on the packaging is an assessment, not an assurance.