Understanding the EU Directive

Empowering Consumers for the Green Transition

As the EU regulation Empowering Consumers for the Green Transition (EmpCo) comes into effect, the way thousands of B2C businesses across Europe communicate their sustainability impact is now under closer scrutiny. What can you say, how should you say it, and what happens if you get it wrong?

This guide, along with our Green claims check-up, will help you navigate the new laws

EmpCo: A bit of background

Ever felt a little suspicious of all those messages in advertisements, websites, on packaging, etc., claiming that a product is the “most sustainable," ”best for the planet,” or “kindest to people”? You’re not alone. More and more consumers feel they can’t trust all these claims, and they are often right. With little regulation around what you can and can’t say about sustainability performance, many companies have overstated how sustainable they are, even if unintentionally.

So, the EU stepped in with EmpCo, a set of rules for companies outlining how to communicate around sustainability. The aim is to help consumers trust and easily understand these messages.

Quick guide

  • Effective from 27 September 2026

  • Applies to B2C companies selling in the EU (although in some markets it’s also relevant for B2B)

  • Individual member states handle implementation plans, enforcement and penalties; this is not handled at the EU level

  • The key benchmark is assessing whether communications could be misleading to the ‘average consumer’

  • The Green Claims Directive is on hold, so this new directive is the one to follow

Eight key areas of EmpCo

These are the eight main areas covered by the Directive that B2B companies with markets in the EU need to follow:

  • Only state future goals, targets or aims, for example, we will reduce emissions by 30% by 2030, if you can support them with clear, objective, publicly available and verifiable implementation plans.

    Plans should demonstrate how commitments and targets will be achieved and financed. Future claims should also be verified and monitored by an independent third party that has relevant experience and competence.

  • If you compare the environmental performance of two products – like a plant-based drink that has 30% fewer emissions than a dairy-based drink – you’ll need to provide detailed information about the method of comparison.

    Only compare products that serve the same function using a common method, assumptions and scope (both should be calculated, for example, from cradle to shelf).

  • Terms like climate neutral, climate positive, carbon neutral or net zero should not be used when the claim is based in total or in part on carbon offsetting. You can only use these terms when they're based on the product's actual lifecycle impact, not on greenhouse gas offsetting.

    Your company can still invest in carbon credit projects and communicate it, but make sure what you say isn’t misleading or implies the product or service has less impact.

  • Only add a label to your product/service if you’re authorised to use it from a certification scheme or a public authority. For example, B Corp-certified, EU Ecolabel, FSC-certified, etc.

    Here’s where you might need to talk to your design team, because anything you create that looks like a label or certification (think green leaf icon, a planet symbol) is prohibited.

  • Don’t use generic environmental claims/language without recognised excellent environmental performance (see the Q&A for details).

    Examples of generic language include ‘environmentally friendly’, ‘ecofriendly’, ‘green’, ‘nature’s friend’, ‘ecological’, ‘environmentally correct’, ‘climate friendly’, ‘gentle on the environment’, ‘carbon friendly’, ‘energy efficient’, ‘biodegradable’, and ‘biobased’.

    Some of these claims, like ‘energy efficient’, could be made if based on recognised excellent environmental performance.

  • Be clear about exactly what part of the product, service or business you’re referring to when making a claim. If it’s only about a certain aspect, don’t infer that it covers more. For example, when a product is marketed as ‘made from recycled material’, it could give the impression that the entire product is made of recycled material, when it only relates to the packaging.

  • You can’t promote something as a consumer benefit if it’s already required by law, e.g., saying a product doesn’t include a banned chemical.

  • If a product has any feature that might limit its life and durability, you should communicate this to resellers and end customers. Marketing goods designed to fail early is prohibited – even unintentional flaws count if the company knowingly continues to sell a product.

    Consumers shouldn’t be persuaded to replace or replenish a product's consumables earlier than necessary and you shouldn’t suggest that third-party accessories will damage the product unless that is truely the case.

    You should provide relevant information about repairability, such as the availability, estimated cost, how to order spare parts, the availability of repair and maintenance and instructions and repair restrictions.

Q&A

  • Corporate sustainability reports — like annual sustainability reports or the disclosures required under the CSRD — usually don't fall under this Directive. That's because these reports are legally required and meant for investors, not for marketing to everyday consumers.

    However, if you use information from a sustainability report in advertising or marketing directed at consumers, this falls under the Directive. We’d also recommend following the directive as closely as possible, even in reporting, as a best practice.

  • Details and specifications to back up a claim should be shown in clear, prominent terms on the same medium as the claim. For example, on packaging, in an advertisement or on a website.

    That said, for claims about future goals, the Directive doesn't require the implementation plan to appear alongside the claim itself. It's enough for the claim to point consumers to where they can find the details — for example, a QR code that links to the plan on a website.

  • Images presented on their own that convey an environmental message (e.g., forests or hands holding saplings) are allowed (but honestly, these images are so cliched avoid them if you can). However, written or oral claims combined with these types of images could be prohibited.

  • Yes, if words like "green," "eco,” "natural" or " planet-friendl“ appear in a brand or product name — and they could make the average consumer think of environmental benefits — the name alone can count as an environmental claim under the Directive, even if it’s registered as a brand name.

  • An example of a generic environmental claim could be "climate-friendly packaging" (with no further detail), and that is banned unless it's backed by genuinely outstanding environmental performance (see next question).

    On the other hand, a claim like "100% of the energy used to make this packaging comes from renewable sources" is specific — it says exactly what's being claimed — so it doesn't fall under the ban on generic claims.

  • You can use an environmental claim like “better for the environment” or “energy efficient” if it is backed up by evidence of so-called excellent environmental performance. This means the claim should be made under one of these recognised schemes:

    • The EU Ecolabel

    • National or regional EN ISO 14024 type I ecolabelling schemes recognised in the Member States, such as the Nordic Swan, Blue Angel, the Austrian Ecolabel, or the Dutch Ecolabel (Milieukeur).

    • A specific, recognised environmental characteristic regulation, such as the Energy Labelling Regulation.

  • Yes, the Directive also applies to claims relating to people, society, working conditions, etc. Examples of what to avoid without substantiation: “No child labour,” “Better for local communities”, etc. If you make these types of statements, back them up with how you monitor this, auditor reports, etc.