EmpCo Directive: What Businesses Need to Know About EU Green Claims and Sustainability Marketing 

The EmpCo Directive is changing how businesses communicate environmental and sustainability claims to consumers in the European Union. From 27 September 2026, companies selling to EU consumers need to pay closer attention to claims such as “eco-friendly,” sustainability labels, carbon-neutral messaging, and statements about product durability or repairability. The rules are designed to give consumers more reliable information and reduce misleading environmental marketing.

For businesses, the practical challenge is not simply understanding what the EmpCo Directive says. It is being able to identify every consumer-facing claim, understand the evidence behind it, review whether that evidence supports the wording used, and maintain a clear record of the review.

Key Takeaways

• EmpCo applies from 27 September 2026, strengthening EU rules on consumer-facing sustainability claims.
• Generic green claims such as “eco-friendly,” “green” or “climate-friendly” need recognised environmental performance to support them.
• Sustainability labels must be based on a qualifying certification scheme or established by public authorities.
• Claims must match the actual scope of the evidence and should not imply benefits for an entire product or business when they apply only to a specific aspect.
• Offset-based carbon-neutral claims face specific restrictions, particularly where they imply that a product has a neutral or reduced climate impact based on external offsets.
• Businesses should connect sustainability claims with reliable, verifiable evidence and maintain clear records to support their communications.

What Is the EmpCo Directive?

The EmpCo Directive is the common name for Directive (EU) 2024/825, formally the Directive on empowering consumers for the green transition through better protection against unfair practices and better information. It amends the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU).

The Directive was adopted on 28 February 2024 and entered into force on 26 March 2024. EU Member States were required to transpose it by 27 March 2026, with the national measures applying from 27 September 2026.

The focus is consumer-facing communication. Businesses should therefore look beyond sustainability reports and examine the claims consumers actually see across product pages, packaging, advertising, labels, e-commerce listings and other commercial communications.

Why Does the EmpCo Directive Matter?

Sustainability has become a major part of product marketing. Words such as green, sustainable, climate-friendly, environmentally friendly and responsible can influence purchasing decisions. The EmpCo Directive raises the standard for how such messages can be presented.

For businesses, this creates a shift from simply having sustainability data to being able to connect that data with the specific claim made to consumers. A claim that sounds broad or positive may still create compliance risk if the business cannot clearly substantiate what the claim means.

Key EmpCo Directive Requirements

1. Generic Environmental Claims Need Strong Support

The Directive adds rules addressing generic environmental claims. Broad statements such as “green,” “eco-friendly” or similar environmental claims cannot simply be used as marketing language without meeting the applicable conditions. The amended rules connect generic claims with recognised excellent environmental performance.

For example, instead of treating “eco-friendly product” as a standalone marketing phrase, a business should be able to explain the specific environmental basis for any permitted claim and maintain evidence that supports the communication.

2. Sustainability Labels Must Meet Specific Conditions

The EmpCo Directive adds a prohibition on displaying a sustainability label that is not based on a certification scheme or established by public authorities. This is relevant for businesses using environmental badges, seals, icons or other sustainability marks in consumer-facing marketing.

Businesses should create an inventory of sustainability labels used across products and marketing channels and identify the scheme, criteria and verification mechanism supporting each label.

3. Environmental Claims Need to Be Defensible

The practical issue behind EmpCo compliance is evidence. When a company communicates an environmental benefit, it needs a defensible basis for that communication. This makes data quality, evidence management and internal review important parts of the marketing compliance process.

For example, a claim about recycled content, responsible sourcing, lower environmental impact or improved resource efficiency should be connected to relevant product, supplier, material or process data rather than existing only as a statement in marketing copy.

4. Carbon-Neutral and Offset-Based Claims Need Particular Attention

Businesses using claims such as carbon neutral, climate neutral or similar compensation-based language should review them carefully against the amended consumer protection rules and applicable national implementation. The key question is not simply whether a company has purchased offsets, but whether the specific consumer-facing claim is permitted and properly supported under the applicable rules.

5. Durability and Repairability Information Is Also Part of the Change

EmpCo is broader than green claims. It also strengthens consumer information around product durability and repairability. The Directive introduces information-related changes through the Consumer Rights Directive, while an EU implementing regulation establishes a harmonised notice and label relating to the legal guarantee of conformity and certain durability guarantees. The implementing regulation applies from 27 September 2026.

Learn how businesses can move beyond sustainability commitments and build transparent, traceable and responsible supply chains with better supplier data, risk management and sustainability evidence.

Read our complete guide to Supply Chain Sustainability and Responsible Business Practices

Who Needs to Pay Attention to the EmpCo Directive?

Businesses that market products or services to EU consumers should assess how the Directive and its national implementing measures affect their consumer-facing communications. This includes manufacturers, brands, retailers, e-commerce businesses and companies outside the EU that market to EU consumers.

The most relevant teams may include marketing, sustainability, legal, product, packaging, e-commerce and compliance. EmpCo should not be treated as a task owned only by the legal team, because environmental claims can appear in many parts of the customer journey.

EmpCo Directive Compliance Checklist

• Identify all consumer-facing environmental and sustainability claims.
• Review product pages, packaging, advertisements, social media, e-commerce listings and labels.
• Map each claim to the evidence supporting it.
• Check whether generic environmental wording is permitted and appropriately substantiated.
• Review every sustainability label, badge, icon or certification mark used in consumer communication.
• Review carbon-neutral, climate-neutral and offset-related claims.
• Check durability and repairability information where applicable.
• Assign ownership for claim approval and evidence management.
• Maintain an audit trail showing the evidence, review and approval behind claims.
• Review national implementation in each EU market where the business sells to consumers.

Why Traceability and Evidence Matter for EmpCo

EmpCo is primarily a consumer-protection and marketing rule, but compliance can depend on information generated much earlier in the supply chain. If a company makes a sustainability claim about sourcing, materials, production or environmental performance, the supporting evidence may sit with suppliers, farms, processors, factories, certification systems or internal operational teams.

This is where traceability and structured evidence management become valuable. A connected system can link a claim to the underlying product, supplier, material, location, transaction or supporting document. Instead of searching across spreadsheets, emails and disconnected repositories, teams can maintain a clearer evidence trail for the information used in consumer-facing sustainability communication.

Connect suppliers, sourcing, production, inventory, batches and shipments to create visibility across your entire supply chain. Learn how digital traceability can improve transparency, strengthen compliance, and support faster response when issues arise.

Read our complete guide to Supply Chain Traceability

How TraceX Can Support Sustainability Data and Evidence Management

TraceX Sustainable Sourcing Solutions helps businesses digitize supply-chain data and connect suppliers, sourcing locations, products, materials, transactions and supporting evidence in one platform. For companies making sustainability-related claims, this can help create a more structured foundation for collecting and maintaining the data behind those claims.

For example, businesses can use TraceX to organize supplier information, map sourcing and production locations, capture sustainability-related data, maintain supporting documents, and connect information across the supply chain. This can make it easier for sustainability, compliance and commercial teams to retrieve the evidence needed during internal reviews.

EmpCo Directive vs. Green Claims Directive

The EmpCo Directive should not be confused with the proposed Green Claims Directive. EmpCo is adopted EU law and applies through amendments to existing consumer-protection legislation. The Green Claims Directive was a separate legislative proposal. Businesses should therefore distinguish between requirements that are already applicable under EmpCo and requirements from proposals that have not become law.

What Should Businesses Do Before 27 September 2026?

The immediate priority is a claim and evidence audit. Start by creating an inventory of sustainability claims and labels used across consumer-facing channels. Then identify the evidence behind each claim, check whether the wording is sufficiently specific, and document the approval process.

The most effective approach is to treat EmpCo as an ongoing governance process rather than a one-time marketing review. Claims change, products change, suppliers change and evidence can expire or become outdated. A repeatable workflow helps businesses keep claims aligned with the information supporting them.

Conclusion

The EmpCo Directive brings sustainability communication closer to the same evidence-driven approach businesses are already adopting for other EU regulatory requirements. From environmental claims and sustainability labels to durability and repairability information, companies need to understand what they communicate to consumers and why they can substantiate it.

For businesses selling into the EU, the key question is simple: can you connect every important sustainability claim to reliable, accessible evidence? Building that connection between claims, products, suppliers and supporting data can make compliance more structured and make sustainability communication more credible.

Frequently Asked Questions (FAQ’s)