September 25, 2026
From Sunday 27 September 2026, the EmpCo Directive makes vague green claims on products sold to EU consumers unlawful. For brands, greenwashing just became a legal risk rather than a reputational one.
That's the date the Empowering Consumers for the Green Transition Directive, better known as EmpCo, starts to apply across the EU. If your packaging, website or social content says "eco-friendly", "climate neutral" or "planet positive", this one is for you.
We've been warning about greenwashing on this blog for a while. Our piece on buzzwords that might be greener than the product they're on looked at how easily sustainability language slips into misleading territory. EmpCo is where those warnings get legal teeth.
In this guide we cover what EmpCo is, exactly what's now banned, how to rewrite the claims most at risk, and the practical steps to take now.
The EmpCo Directive, also known as the ECGT Directive, is Directive (EU) 2024/825. It has been EU law since March 2024. It doesn't create a brand-new rulebook. Instead, it amends two directives you may already know: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU).
Its aim is simple: stop misleading environmental claims and make sustainability labels mean something. It covers business-to-consumer communication in every form, including on-pack claims, product pages, adverts, emails and influencer posts.
Not every Member State hit the March deadline. Germany (through its unfair competition law, the UWG) and Italy (through its Consumer Code) are among those that have. But 27 September is the date to plan around, and enforcement will come through national consumer authorities, courts and, in some countries, competitor challenges.
Under the Unfair Commercial Practices Directive as already amended, authorities can impose fines of at least 4% of annual turnover for widespread cross-border infringements. Add product withdrawals, relabelling costs and the reputational hit of a public ruling, and this is not a paperwork exercise.
EmpCo adds new practices to the EU "blacklist", meaning they are treated as unfair in all circumstances. There's no case-by-case assessment and no "but consumers understood what we meant" defence.
Terms like "eco-friendly", "green", "environmentally friendly", "climate friendly" or "ecological" are banned unless you can demonstrate recognised excellent environmental performance relevant to the claim. In practice, very few products will clear that bar, so the safest route is to replace them with specific, evidenced statements.
A sustainability label must now be based on a certification scheme or established by a public authority. That little leaf badge your design team created in-house? If it isn't backed by a qualifying scheme, it has to go. The European Commission's guidance does allow a brand to own its scheme, but only if the scheme itself meets the certification requirements, including independent monitoring.
You can't make an environmental claim about the entire product, or your entire business, when it only relates to one part of it. Recycled-content packaging does not make the product "sustainable", and one responsibly sourced ingredient does not make the formula "green".
Claiming a product is "climate neutral", "carbon neutral" or has a reduced climate impact on the basis of offsetting emissions is banned. You can still talk about offsetting as part of your wider climate activity. You can also make claims based on genuine, evidenced reductions across the product's life cycle.
If the law requires every product in the category to meet a standard, you can't present it as something that sets yours apart. Look closely at any on-pack "free from" or compliance-style claims that simply describe the legal baseline.
Statements like "net zero by 2030" now need clear, objective and verifiable commitments, a detailed and realistic implementation plan, and regular monitoring by an independent expert, with the findings made available to consumers.
EmpCo also brings in rules on durability, repairability and software updates, including a ban on hiding planned obsolescence. These matter most for goods with digital elements, which includes some connected medical devices, wearables and wellness tech.
EmpCo applies alongside your sector rules, not instead of them. It's an extra layer on top of the claims frameworks you already work within.
Beauty leans heavily on sustainability language: "clean", "conscious", "reef safe", "planet-friendly". Any of these that imply an environmental benefit now need to be specific and evidenced, or removed. Your claims must still meet the EU common criteria for cosmetic claims too, so a claim has to pass both tests. Refill and packaging claims are a particular hotspot.
Related: Clean Beauty Doesn't Actually Mean Anything
Supplement brands often pair health claims with eco messaging on pack, from "plastic-free" pots to "sustainably sourced" ingredients. Health claims remain governed by the Nutrition and Health Claims Regulation, while environmental claims now fall squarely under EmpCo. Watch for whole-product claims built on a single ingredient or a single packaging change.
Related: Why should food supplement companies review their labels often?
For devices, the durability, repairability and software update rules are as relevant as the green claims ban. If you sell consumer-facing devices with digital elements, check what you say about product lifespan and updates. Any environmental claims about materials or packaging need the same scrutiny as any other product.
Wherever you sit, remember that EmpCo applies to what you say, wherever you say it. A compliant label paired with a non-compliant TikTok caption is still a problem.
No, and this is the misunderstanding we hear most. In June 2025 the European Commission announced it intended to withdraw its proposed Green Claims Directive. That was a separate law that would have added detailed pre-verification of claims, and it has stalled.
EmpCo is a different piece of legislation. It was adopted in 2024 and applies from 27 September 2026 regardless of what happens to the Green Claims proposal. The stalled directive would have changed the paperwork; EmpCo already changes what you're allowed to say.
EmpCo doesn't apply in Great Britain, but it does apply to anything you sell to consumers in the EU. If you ship to EU customers, run an EU-facing website or sell through EU retailers, your EU claims need to comply.
The UK isn't a free pass either. The CMA's Green Claims Code sets similar expectations, and the Digital Markets, Competition and Consumers Act 2024 gave the CMA power to fine businesses directly for unfair consumer practices. The ASA continues to rule on environmental ads too. Getting your claims EmpCo-ready will put you in a strong position on both sides of the Channel.
If you haven't started, start this week. These six steps will get you most of the way.
Packaging already in production is a common worry. Rules differ between Member States on how existing stock is treated, so take advice before assuming a sell-through period applies to you.
Related: When Packaging Looks Good but Fails Compliance: Common Issues in Cosmetic Products
Does EmpCo apply to B2B communications? No. It covers business-to-consumer practices. But claims made to retailers often end up in front of consumers, so it's wise to apply the same standard.
Can I still say my packaging is recyclable? Yes, if it's true and specific. Say what is recyclable (the bottle, the cap, the carton) and make sure it can genuinely be recycled in the markets where you sell.
Can I still mention carbon offsetting? Yes, as part of describing your wider climate activity. What you can't do is use offsets to claim a product is climate neutral or has a reduced climate impact.
What if a Member State hasn't transposed EmpCo yet? The 27 September application date still applies. Late transposition creates uncertainty about local enforcement, but it's not a reason to keep non-compliant claims, especially if you sell across several EU markets.
Does "natural" count as an environmental claim? Not automatically. It depends on context and whether it implies an environmental benefit. "Natural" in cosmetics also has its own claims considerations, so it's worth reviewing case by case.
EmpCo rewards brands that can back up what they say, and that's exactly where we work. Our team reviews claims across cosmetics, food supplements and medical devices every day. We can audit your packaging, website and marketing against EmpCo alongside your sector-specific rules, and help you rewrite claims so they still sell.
Not sure where your claims stand? Get in touch and we'll help you work out what stays, what changes and what needs to go, before a regulator or competitor asks the question for you.
