Sustainable-cotton claims: substantiation checklist

What changed in July 2025

The Commerce Commission closed the matter with a warning concerning substantiation of a sustainable-cotton claim. A warning records the regulator’s view, not a judicial finding.

What businesses should do now

Define the represented product, material, supply-chain stage and environmental attribute, then retain evidence that supports the claim at the time it is made.

• Define the represented product, material, geography, supply-chain stage and attribute.
• Trace each material claim to current product- and supplier-specific evidence.
• Test certification, transaction, mass-balance or chain-of-custody limitations before use.
• Record evidence gaps, assumptions, approval conditions and recheck triggers.
• Monitor supplier, product, material and programme changes that could invalidate the claim.

Evidence to retain

• Final claim wording, product scope and approval conditions.
• Supplier declarations, certificates, transaction records and chain-of-custody evidence.
• Methodology, calculation, sampling and material limitations.
• Change notices, corrective actions, rechecks and withdrawal decisions.

Turn the issue into a controlled decision

• Record the affected product, claim, customer journey, system, supplier or business process.
• Separate current requirements from proposals, priorities, allegations, warnings and matter-specific outcomes.
• Assign an owner, action date and evidence location for every material gap.
• Set review triggers for legal changes, new facts, supplier changes, incidents, complaints and campaign variations.
• Escalate when the available facts or evidence do not support the proposed decision.

Questions to ask

Focus on the decision and the evidence.

1. 01

   What exact product, material, supplier and supply-chain stage does the claim cover?

2. 02

   Does current evidence support the represented environmental or sourcing attribute?

3. 03

   What changes, gaps or corrective actions would require the claim to stop or change?

Primary sources

Check the controlling material.

• Official regulator information ↗

Related resources

Continue with this topic.

Recommended training

Practical support

Apply the guidance to your facts.

Identify the exact product, claim, customer journey, supplier, legal entity or process involved. Preserve the information that supports the current position, record unresolved facts, assign an owner and confirm the point at which specialist review is required.

Important information

Check the current position.

This resource is general information, not legal advice. Laws, official guidance and proposals can change. Do not rely on a title or summary alone to decide whether a requirement applies to a particular entity, product or activity.