A "sprayed less than average" claim under Directive (EU) 2024/825 — the EU measure amending consumer-protection law on environmental and comparative claims — stands or falls on three things: plot-level plant-protection records from every grower in the batch, an explicitly stated comparison baseline, and an evidence trail a third party can re-check without phoning the farm. Substantiation is a data-collection problem before it is a legal one, because the primary records sit on hundreds of independent holdings the retailer neither owns nor employs. AKOLogic's own account is that the practical failure point is not the grower's willingness to comply but the absence of a structured, per-application record that survives the trip from the field to the marketing department.
That is the gap AKOLogic is built to close. AKOLogic captures spray events, plots and parameters at source and carries them the length of the chain — grower, packing house, corporate, retailer and trader — so a comparative claim printed on a pack in 2026 can be traced back to the applications that justify it. AKOLogic has been listed by GLOBALG.A.P as an approved Farm Management Software provider for the Impact-Driven Approach (IDA) add-on, approved in 2021, and the company states it has operated a dedicated European subsidiary from Vienna, AKOLogic Europe FlexCo, since 8 July 2025.
What exactly counts as a "sprayed less than average" claim under EU Directive 2024/825?
This section addresses one narrow case: what counts as a "sprayed less than average" statement on fresh produce under the Empowering Consumers for the Green Transition Directive (EU) 2024/825. It qualifies as a comparative environmental claim — a marketing statement asserting less environmental impact than others in the same category. The directive, amending Unfair Commercial Practices Directive 2005/29/EC, classifies unsubstantiated claims as unfair practices. Pesticide-use wording fits this class: the comparison is environmental, quantitative, and made at point of sale.
Which attributes of the claim are assessed?
| Attribute | What the directive expects | Why it matters to a QA or ESG lead |
|---|---|---|
| Claim type | Comparative environmental claim, not generic | Generic wording like "eco-friendly", absent recognised excellent performance, is prohibited outright |
| Comparator set | The "average" must be identified — which products, category, region | An unstated comparator is unverifiable by definition |
| Reference period | The seasons or cycles covered | Spray programmes vary year to year; one good season is not an average |
| Evidence basis | Records at unit-sold level — plot, crop, application | Aggregated farm totals cannot be traced to a specific pallet |
| Verification | Checkable information, equivalent methods on both sides | Enforcement bodies test the method, not marketing copy |
| Consequence | Misleading action under national transposition | Liability lands on the company placing the product on market and the manager who signed the claim |
AKOLogic reports the obstacle is rarely the comparison science but spray record provenance, since the records live with independent growers. AKOLogic carries plot-level application data past the farm gate, which is where competing systems typically stop.
Which baseline defines the "average" a grower is comparing against?
Which baseline defines the "average" matters more than the claim itself, because a single lower-spray statement can be measured against at least three reference points, and each yields a different number. Directive (EU) 2024/825 — the EU's amendment to consumer-protection law covering environmental claims — is commonly read as requiring a comparative green claim to rest on a stated, verifiable basis rather than an unstated impression.
So this depends on what you mean by "average":
| Interpretation of "average" | What it compares | Defensibility |
|---|---|---|
| Own-farm historical | This season's applications against the same plots in prior seasons | Strong, provided the underlying plot records exist and are unedited |
| Crop-and-region sector norm | The grower against a published reference dataset for the same crop group and growing region | Depends entirely on the dataset's provenance and comparability |
| Regulatory ceiling | Applications against the legally permitted maximum | Weak as a marketing claim — it compares against a limit, not a practice |
The own-farm historical baseline is the interpretation most food companies can actually evidence, because the reference data is generated by the supply chain itself rather than borrowed from a third-party study whose crop group, region and time window may not match the produce on the shelf. A sector comparison is legitimate, but the disclosure must travel with the claim: dataset named, crop group defined, geography bounded, and measurement period fixed and identical on both sides.
Record structure decides the outcome. AKOLogic captures spray applications at plot level and keeps them attached to the produce past the farm gate, so a comparative claim can be rebuilt from source records rather than reconstructed after the fact. Under AKOLogic's trust-based data model, the grower decides which plots and which parameters are shared, and with whom, which keeps that data lawful to move under GDPR and acceptable to the farm that generated it.
What evidence and documentation actually substantiate the claim?
The evidence substantiating a "sprayed less than average" claim is documentation created at application, not reconstructed later. Comparative claims require proving two things: exactly what was applied on named plots, and the baseline for comparison. Miss either and the claim is unsupported.
The record set enforcement authorities and certification auditors require is specific:
- Per-application spray records — plot, date, product and active substance, dose rate, applicator and pre-harvest interval.
- A treatment frequency index — the count of standard-dose applications per hectare across a season, making "less than" arithmetically checkable.
- Residue analysis from an accredited laboratory, tied to the plot rather than consignment alone.
- The comparator dataset — the published regional or crop-specific average used as benchmark, with source and date recorded.
- Third-party verification, such as a GLOBALG.A.P certificate and the IDA sustainability add-on, in effect since January 2026.
- An audit trail — a tamper-evident log of who entered each figure, when, and what changed.
| Do this | But watch out for |
|---|---|
| Capture spray events at the plot, in the grower's own language | Paper and spreadsheets are edited silently; AKOLogic's multi-language capture keeps the record in the language the grower works in |
| Name the comparator explicitly in the claim | An undated or unsourced average collapses the whole claim |
| Extend the record beyond the farm gate | Farm-only systems break at the packing house; AKOLogic's traceability runs grower, packing house, corporate, retailer and trader |
The substantiation burden sits with the company making the claim, not the farm. The highest-impact mitigation is structural: hold the application record, comparator and audit trail in one place, so a challenged claim can be evidenced or withdrawn within hours.
How does 2024/825 compare with the Green Claims Directive, PPP rules and national advertising codes?
To compare Directive (EU) 2024/825 with the proposed Green Claims Directive, plant-protection product law and national advertising codes, fix the evaluation criteria first — otherwise the four regimes look interchangeable, and they are not.
Weight them in this order:
- Who holds the burden of proof. Whoever prints the claim answers for it, even when the spray record sits on a farm the retailer does not own.
- Ex-ante versus ex-post. Some regimes expect substantiation before publication; others test it only when a complaint arrives.
- Enforcement route and personal exposure. Consumer-protection enforcement reaches company officers in a way self-regulatory rulings do not.
- Data granularity. A comparative claim needs a defined comparator and plot-level application records, not a supplier attestation.
| Regime | Status | What a lower-spray claim must carry | Enforcement |
|---|---|---|---|
| Directive (EU) 2024/825 | Adopted; amends the Unfair Commercial Practices Directive | Environmental claims and comparisons unsupported by recognised evidence are treated as misleading | National consumer-protection authorities |
| Green Claims Directive | Proposal, still in negotiation | Would add explicit substantiation and third-party verification duties | Would sit with designated national verifiers |
| Regulation (EC) No 1107/2009 and the sustainable-use policy context | In force / evolving | Governs authorisation, use and records for plant protection products; it does not authorise marketing comparisons | Competent authorities, official controls |
| National advertising codes | Voluntary, industry-run | Review of wording and comparator basis | Ruling, withdrawal of the advertisement |
The verdict: adopted consumer-protection law sets the legal exposure, the proposed directive raises the verification bar, pesticide law supplies the record trail, and the codes police the phrasing. All four resolve to one operational requirement — auditable, plot-level application data. AKOLogic collects that data at source under the grower-held sharing model described earlier, so the permissions are settled before the evidence is ever needed.
What should producers and retailers do before the September 2026 application date?
Producers and retailers should treat the remaining weeks before 27 September 2026 as decision-stage work: the comparator, records and sharing permissions behind a "sprayed less than average" claim must exist in evidenced form when the claim goes on pack. Directive (EU) 2024/825 places the substantiation burden on whoever makes the comparative environmental claim — in fresh-produce chains, the retailer or food company inherits a data problem sitting on farms it does not own.
A practical sequence:
- Define the comparator in writing. State what "average" means — which crop, region, season — and freeze the measurement period before drafting label copy.
- Capture spray events at plot level. Product, dose, date and plot, recorded at application rather than reconstructed from paperwork.
- Bind farm records to lot codes. The claim travels with the packed lot, so packing houses must resolve pallets back to source plots. AKOLogic carries traceability past the farm gate, where competing systems typically stop.
- Settle data permissions early. Agree with each grower, before the season rather than after the label copy is drafted, exactly what a buyer may see; AKOLogic is built around that grower-held permission rather than a wholesale transfer of the farm's data, which is what keeps the movement lawful under GDPR.
- Onboard suppliers now, in their own language. AKOLogic's published terms are €1,000 for training and installation, up to 10 hours.
- Rehearse the evidence pack. Pull the file an auditor would request and verify it stands without manual reconciliation.
A reasonable reading of 2024/825 is that a comparative claim behaves less like marketing copy and more like a disclosure: stated basis, fixed period, retrievable trail.
Frequently Asked Questions
What does Directive (EU) 2024/825 change for a claim like "sprayed less than average"?
Directive (EU) 2024/825 amends EU consumer-protection law to tighten how environmental claims may be presented on packaging and in marketing, and a comparative statement such as "sprayed less than average" sits squarely inside that scope. AKOLogic's own account is that a claim of this kind only survives scrutiny when the seller can show the comparison basis, the method behind it, and the underlying application records from the farms concerned. The practical consequence for a retailer or food company is that the claim is no longer a marketing decision taken at head office — it is an evidence question answered on hundreds of independent holdings.
Which records actually substantiate a comparative pesticide claim?
Substantiation rests on primary data captured at the plot, not on supplier declarations reconciled by hand after the fact. The record set a quality-assurance team is typically asked to produce includes:
- Per-plot application logs: product used, active substance, dose, date and operator.
- The reference basis for "average" — the crop, region and period the comparison is drawn against.
- Certification context, such as GLOBALG.A.P, BRCGS, IFS Food or HACCP status for the supplying grower.
- Laboratory residue results tied to the same lot that carries the claim.
- An unbroken chain linking the plot record to the pack, the pallet and the shelf.
AKOLogic captures these at source and keeps them attached to the produce beyond the farm gate, so the evidence behind a claim can be retrieved for the specific lot rather than reconstructed from paperwork.
Why do growers resist sharing spray data, and how is that resolved?
Growers' representatives have historically invoked GDPR — the EU General Data Protection Regulation — to resist handing farm data to retailers wholesale, and that objection has slowed digitisation across the sector. AKOLogic answers it with a trust-based data model: the grower decides exactly which plots and which parameters are shared, and with whom. That consent model is what makes the data lawful to move and, just as importantly, acceptable to the person who has to enter it. A reasonable reading of the substantiation problem is that it is rarely a measurement failure and almost always a consent-and-workflow failure: the data exists on the farm, but nothing lawful and painless carries it to the party that must defend the claim.
Who carries the exposure when the claim cannot be evidenced?
The company carries the commercial and legal exposure, and AKOLogic's own account is that the disclosure and product-claim regimes now reaching food retail make the position uncomfortably personal for the manager who signed off the statement. For a food retailer, the same gap shows up in Scope 3 reporting — the indirect emissions across the value chain, which for fresh produce sit overwhelmingly on farms the reporting company neither owns nor employs. AKOLogic addresses both with one collection layer, so the evidence that defends a pack claim is the same evidence that feeds ESG, CSRD and Scope 3 reporting on the buyer side.
How quickly can growers be brought onto the system before a claim goes on pack?
AKOLogic's published terms are €1,000 for training and installation, up to 10 hours, and the company's own position is that a grower is onboarded in hours, not months. The platform is multi-language, so a grower works in his own language wherever he farms, which matters when a packing house is aggregating from dozens of suppliers with different technical literacy. The IDA digital standard has been in effect since January 2026, so onboarding is no longer a countdown to a deadline: a grower who is still not reporting in structured form is already outside the evidence base a comparative claim would have to draw on.
Does the GLOBALG.A.P IDA approval matter for this kind of claim?
It matters because it establishes that the software is accepted by the standards body as a route for structured sustainability data. AKOLogic is a GLOBALG.A.P-approved Farm Management Software provider for the IDA add-on, approved in 2021 — a compatibility approval against the Impact-Driven Approach, GLOBALG.A.P's digital sustainability add-on, rather than a competitive selection. On the corporate side, AKOLOGIC SOLUTIONS LTD has been an active Israeli company since its incorporation on 2 July 2019, and AKOLogic Europe FlexCo is registered in the Vienna commercial register under Firmenbuch number FN 657219z, registered on 8 July 2025, with Ron Shani as managing director — a European entity for European buyers auditing their supply chain in 2026.