Claims & Market Communication
Governed by the integration rule document. Core scope: Green Claims and Empowering Consumers for the Green Transition (EmpCo). This domain governs the evidence and authority needed before sustainability information becomes a market-facing assertion.
2026-W38 authority register
| ID | Finding | Authority / disposition |
|---|---|---|
| CM-01 | EmpCo, Directive (EU) 2024/825, is adopted legislation and applies from 27 September 2026, subject to national implementation and jurisdictional applicability. | LEGAL_ACT; near-term CANONICAL_REVIEW_REQUIRED. |
| CM-02 | The Commission's Green Claims page still describes the Green Claims Directive as a proposal. Its exact procedure/withdrawal state requires legislative-record confirmation before relying on it. | PROPOSAL; AWAIT_AUTHORITY. |
| CM-03 | Commission/CPC sustainable-consumption enforcement material is a supervisory/enforcement signal, not a universal statutory exemption or new general duty. | SUPERVISORY_SIGNAL; WATCH. |
Architecture Integration decision
The central rule is:
A calculated, verified or disclosed sustainability result is evidence. It is not publication authority.
EmpCo's imminent application makes this domain operationally important now. Green Claims must remain a separate candidate policy and cannot delay or expand EmpCo obligations.
A governed claim/publication decision should bind:
- exact wording and language;
- claim subject and product/entity scope;
- audience/channel;
- jurisdiction and applicable consumer-law profile;
- period/validity;
- methodology/result version;
- evidence snapshot and provenance;
- limitations, uncertainty and fallback conditions;
- verification/assurance state;
- permitted wording/qualifiers;
- reviewer/authority;
- approval/rejection decision;
- expiry/review trigger;
- publication/withdrawal history.
Canonical review found existing ZAYAZ publication-authority concepts and a Green Claims SSSR tag, but this cycle has not yet verified a complete claim-specific publication gate. Therefore unregistered candidate: sustainability claim publication gate is elevated but not ready.
Disposition: EmpCo CANONICAL_REVIEW_REQUIRED; Green Claims AWAIT_AUTHORITY.
Rights and evidence reuse
Claim evidence must compose with canonical Pergamum Pulse rights. Evidence being available internally does not mean it is permitted for public_generation, external publication or redistribution. Restricted supplier evidence may support an internal decision without being exposed in the published claim.
Acceptance criteria
| Scenario | Expected behavior |
|---|---|
| Product result exists but method/boundary does not support the wording | Claim remains unapproved with a recorded evidence gap. |
| PEF result uses transitional fallback/omission | Claim reviewer sees the original limitations and comparability constraints. |
| Green Claims proposal changes | Candidate policy changes only; no binding EmpCo behavior is removed or expanded. |
| 27 September 2026 arrives | Resolve applicable national EmpCo rules/jurisdiction before publication decisions. |
| Evidence is superseded | Trigger review of dependent published claims while preserving the historical approval basis. |
| Evidence is restricted for public generation | Block unsupported publication even if evidence is valid for internal analysis. |
| CPC/enforcement statement concerns a narrow fact pattern | Do not convert it into a universal rule without scope analysis. |
Cross-regime collisions
X-05 — footprint/claim. Product Sustainability supplies evidence, methodology and limitations; Claims owns publication eligibility.
X-09 — EmpCo/Green Claims. Binding EmpCo obligations and the Green Claims proposal remain independent authority tracks.
Corporate Disclosure reports do not automatically substantiate product advertising. Sustainable Finance statements require their own finance marketing/disclosure rules. Regulatory Infrastructure supplies rights/provenance and publication events but not claim wording authority.
Canonical specs requiring review before Hecate readiness
- Constitutional Publication Framework;
- any existing claim/publication approval specification;
- SSSR Green Claims routing semantics;
- TrustGate/AAE evidence and assurance contracts;
- national/jurisdictional consumer-law profile model;
- publication rights and
public_generationhandling.
unregistered candidate: sustainability claim publication gate should only be drafted after confirming whether those assets already provide the publication gate and identifying the precise missing responsibility.
Weekly cohort history
| Cohort | Intelligence retained | Integration decision |
|---|---|---|
| 2026-W36 | No claims-specific intake | NOT_ASSESSED. |
| 2026-W37 | ORBIT mentioned Green Claims | Research connection only. |
| 2026-W38 | Green Claims/EmpCo promoted to core; EmpCo 27 September application | Integrated 2026-09-15: prioritise EmpCo/national applicability and claim publication authority; keep Green Claims proposal staged. unregistered candidate: sustainability claim publication gate elevated pending canonical publication review. |
What changed in ZAYAZ? Claims governance became a near-term architecture review because EmpCo applies on 27 September 2026. No marketing rule was activated; the next step is to reconcile existing publication/rights architecture and define only the missing claim-specific gate.
2026-W39 Architecture Integration
Authority recheck
| ID | Finding | Classification / disposition |
|---|---|---|
| CM-W39-01 | EmpCo (Directive (EU) 2024/825) applies from 27 September 2026. | LEGAL_ACT; CLAIMS_CHANGE, EFFECTIVE_DATE_DELTA; CANONICAL_REVIEW_REQUIRED. |
| CM-W39-02 | The Commission continues to describe the Green Claims Directive as pending; Parliament's procedure file records it as awaiting the Council's first-reading position. | PROPOSAL; AWAIT_AUTHORITY. |
| CM-W39-03 | Commission/CPC guidance and common understandings remain enforcement/support signals, not substitutes for the applicable national consumer-law rules. | SUPERVISORY_SIGNAL; WATCH. |
Architecture decision
The claims domain is now the most time-sensitive WSI review because EmpCo application is imminent.
Canonical search shows that ZAYAZ already contains:
- Constitutional Publication Framework concepts;
- publication/disclosure routing;
- Green Claims SSSR tagging;
- Pergamum Pulse rights/public-generation boundaries;
- conformance/certification treatment of public claims;
- PEF roadmap rules for comparative claims.
The missing responsibility is therefore likely narrower than a new claims subsystem: a jurisdiction-aware sustainability claim admission profile that binds exact wording to evidence, calculation limits, consumer-law rule version and publication authority.
unregistered candidate: sustainability claim publication gate is elevated to READY_FOR_DETAILED_CANONICAL_REVIEW, but not yet READY_FOR_NEED_DRAFT until the existing publication/admission contracts are read in full and Norwegian/EU national implementation profiles are identified.
Acceptance criteria
- EmpCo applicability is resolved independently of Green Claims status.
- A valid PEF/PCF result does not grant publication authority.
- Claim review receives fallback, uncertainty, verification and comparability limitations from source calculations.
- Restricted evidence may support an internal admission decision without being publicly disclosed.
- A claim approved under one jurisdiction/profile is not silently treated as approved everywhere.
- Green Claims proposal requirements remain staged and cannot create production obligations.
W39 history
What changed in ZAYAZ? Claims governance moved from “near-term review” to immediate canonical admission/publication review because EmpCo applies on 27 September. No marketing rule was activated and Green Claims remains proposal-stage.
W39 source/evidence register
All entries below were retrieved/rechecked 2026-09-22.
| Event | Authoritative source | Locator |
|---|---|---|
| CM-W39-01 | European Commission — Sustainable consumption; EUR-Lex — Directive (EU) 2024/825 | Commission states Member State transposition deadline 27.03.2026 and application from 27.09.2026. |
| CM-W39-02 | European Commission — Green Claims; European Parliament — 2023/0085(COD) | Proposal/procedure sources; no production obligation inferred from proposal-stage text. |
| CM-W39-03 | European Commission — Sustainable consumption enforcement actions | CPC/enforcement material treated as supervisory/enforcement signal, not as a universal statutory rule. |