On 27 September 2026 the rules changed across the European Union. Under Directive 2024/825, known as EmpCo, a generic environmental claim with no proof behind it, “green”, “eco-friendly”, “sustainable”, an offset-based “carbon neutral”, is now a banned commercial practice, enforced through national law, with penalties that can reach into the low single-digit percentages of annual turnover. The burden has inverted. It is no longer on the regulator to prove your claim is misleading. It is on you to prove it is true.
The energy sector has spent two years as the worked example of what happens when you cannot. European regulators opened action against twenty airlines over claims that a flight could be made “carbon neutral” through offsets, and over the loose use of “sustainable aviation fuel”, and the airlines agreed to drop the language. A French court and the UK advertising regulator both found against an oil and gas major’s “carbon neutral by 2050” and renewables-forward advertising, because the ambition outran the evidence shown. An Australian retailer withdrew a “carbon neutral” energy product and apologised to its customers. A fuel major’s “CO₂ neutral” driving campaign was ruled misleading because it could not show the offsets fully cancelled the emissions. Different countries, different regulators, one pattern: the claim lived on the website, and the evidence lived nowhere anyone could produce on demand.
That gap was always a reputational risk. Two things turned it into an operational one. The first is the law, now in force. The second is quieter and larger: the same unbacked claim an inspector reads on your site is the claim an AI agent retrieves and repeats to a customer, at machine speed, with total fluency, stripped of whatever caveat a person might have inferred. An estate full of claims nobody connected to evidence is a liability pointed at two audiences at once, and neither accepts “it was true when we wrote it”.
A claim without a source is now a liability with an audience.
The root cause is mundane and universal. A claim and its evidence are made by different people, at different times, and kept in different places. Marketing writes “40% lower carbon”. The number came from a life-cycle assessment in a consultant’s PDF, a supplier certificate, a slide from eighteen months ago. The claim goes live on the site. The evidence goes into a folder, a deck, somebody’s inbox. Nothing connects them, so when an auditor, a journalist, a customer or an agent asks “says who?”, there is no answer to produce in the moment. The claim is an orphan, exactly like the pages in the rest of this series, except this orphan is now unlawful.
Sage does the first part of that job. She reads every page, and for each one she writes down the claims: a number, a price, a certification or regulatory statement, a named partner, a date. Not sentiment, not tone. Each comes back with the exact words and the page it sits on, so the list that every marketing team currently keeps from memory exists in one place, estate-wide. Where two pages state the same thing differently, Cedar shows both. Whether a claim has evidence behind it is your answer to give; woods does not hold your evidence, and does not tell you a claim is true or lawful. That is for you and your counsel.
Finding the claims is the half of the problem you can see. The other half, giving every claim a permanent, current home for its proof so that “prove it” has an answer before anyone asks, is the half woods does not do: that register is yours to keep.
This is a description of the rules, not legal advice. woods supports governance and documentation; it does not make anyone compliant.