Is Your Website EmpCo-Compliant? A Practical Compliance Checklist for Marketing Teams

Your website is probably one of the first places consumers encounter your environmental claims. Whether it is a product page describing materials, a sustainability page explaining your environmental goals or a banner promoting a "greener" product, these statements all contribute to how consumers understand your environmental performance. Under the Empowering Consumers for the Green Transition Directive (EU) 2024/825, better known as the EmpCo Directive, businesses need to take a closer look at how these claims are presented and whether they can be substantiated.

This matters because EmpCo does not only concern obvious greenwashing. The Directive also considers how environmental claims are communicated through images, symbols, labels and the overall impression created by a commercial communication. A website can therefore contain compliance risks that are not immediately obvious when you simply search for words such as "sustainable" or "eco-friendly".

With the rules in force since 27 September 2026, every claim on your website is exposed today. The following checklist can help you identify the areas that deserve the most attention.

1. Start by finding every environmental claim

Before you can assess whether your website is compliant, you first need to know what environmental claims are actually being made. This sounds straightforward, but larger websites can contain hundreds or even thousands of pages, with claims appearing in product descriptions, campaign landing pages, blogs, category pages and other content.

It is also important to remember that an environmental claim does not have to be a sentence containing an obvious green marketing term. Under EmpCo, environmental claims can be communicated through text, images, graphics, symbols, labels, brand names and product names when they create an environmental impression.

Start by reviewing areas such as:

• Product and category pages
• Homepage and landing pages
• Sustainability and ESG pages
• Paid campaign landing pages
• Blog articles and downloadable content
• Product images and icons
• Environmental labels and badges
• Claims included in navigation or promotional banners

The objective at this stage is not to decide whether every claim is compliant. It is to create a complete picture of what your website is communicating. Once you know where the claims are, you can start assessing them.

2. Check your generic environmental claims

One of the first things marketing teams should look for is broad or generic environmental language. Words and phrases such as "eco-friendly", "green", "environmentally friendly", "climate-friendly", "energy efficient", "biodegradable" and similar expressions can create the impression that a product has excellent environmental performance.

EmpCo prohibits generic environmental claims when the business cannot demonstrate recognised excellent environmental performance that is relevant to the claim. Importantly, the Directive does not simply create a list of words that are always forbidden. A generic claim can be treated differently when its specification is provided clearly and prominently on the same medium.

For example, compare these two statements:

"Climate-friendly packaging"

and:

"100% of the energy used to produce this packaging comes from renewable energy sources."

The second statement is much more specific about what environmental characteristic is being communicated. However, being specific does not automatically make a claim compliant. The underlying statement still needs to be accurate and properly substantiated.

When reviewing your website, ask:

• Are we using broad environmental terms?
• What exactly does each term mean in this context?
• Is the relevant environmental performance recognised and demonstrable?
• Is the specification of the claim clear and prominent on the same page or interface?
• Does the evidence support the entire claim?

This is often a good starting point because generic environmental language can appear throughout a website without being managed as a single set of claims.

3. Look at the scope of every claim

A common compliance problem is making a claim about an entire product when the environmental benefit actually applies only to one part of it. EmpCo specifically prohibits environmental claims about an entire product or an entire business when the claim concerns only a particular aspect or a specific, unrepresentative activity.

Imagine a product page stating:

"Made with recycled materials."

The product itself may contain some recycled material, but what if only the packaging is made from recycled content? A consumer could interpret the statement as meaning that the entire product is made with recycled materials. The underlying fact may be true, but the overall impression can still be misleading.

The same issue can occur at company level. A business might communicate that it "uses renewable energy" because one facility runs on renewable electricity, while several other facilities continue to use fossil fuels. The claim may therefore create a broader impression than the evidence supports.

When reviewing website copy, ask whether the scope of the claim matches the scope of the evidence. If the environmental benefit applies only to a component, material, location or specific activity, the wording should make that limitation clear.

4. Review your sustainability labels and badges

Your website may contain more sustainability labels than you realise. Look at product badges, certification logos, "green choice" symbols, trust marks and other visual elements that could suggest that a product has particular environmental credentials.

EmpCo prohibits displaying a sustainability label that is not based on a certification scheme or established by public authorities. Certification schemes themselves need to meet requirements relating to transparency, credibility and monitoring.

This means your review should not stop at the text on a page. Look at the visual communication surrounding your products as well. A green icon or certification-style badge can influence how consumers interpret the product, even when the surrounding copy is relatively careful.

For every sustainability label or badge on your website, consider:

• What does this label actually represent?
• Who operates the scheme?
• Is it based on a certification scheme?
• Is the scheme independently monitored?
• Can consumers easily understand what the label means?
• Does the product actually meet the relevant requirements?

If the answer to these questions is unclear, the label deserves further investigation.

5. Check your carbon-neutral and climate claims

Carbon-related claims should receive their own review because EmpCo specifically addresses claims based on the offsetting of greenhouse gas emissions. The Directive prohibits claims that a product has a neutral, reduced or positive environmental impact in terms of greenhouse gas emissions when that claim is based on offsetting outside the product's value chain.

That means marketing teams should search their websites for phrases such as:

• "Carbon neutral"
• "Climate neutral"
• "CO₂ neutral"
• "Carbon positive"
• "Net zero"
• "Climate compensated"
• "Reduced climate impact"
• "Limited CO₂ footprint"

Finding one of these terms does not mean that you can immediately conclude that the page is non-compliant. The important question is how the claim is formulated and what it is based on. The Directive distinguishes between a claim about the actual lifecycle impact of a product and a claim based on offsetting greenhouse gas emissions outside the product's value chain.

This is also a good example of why simply using a keyword search is not enough. You need to understand the context of the claim, the evidence behind it and what impression a consumer is likely to take from the page.

6. Review future environmental commitments

Does your website contain statements about what your company intends to achieve in the future? Claims such as:

"We will be carbon neutral by 2030."

"Our products will be fully recyclable by 2028."

"We aim to reduce our emissions by 50%."

can all communicate future environmental performance.

Under EmpCo, certain claims about future environmental performance need to be supported by clear, objective and publicly available commitments, measurable and time-bound targets, a detailed and realistic implementation plan and appropriate resources. The implementation of the commitments also needs to be subject to regular verification by an independent third-party expert, with the findings made available to consumers.

This means a marketing team should not assume that an ambitious sustainability target is automatically suitable for use as a consumer-facing claim. If your website communicates future environmental performance, make sure the underlying plan, targets and evidence can support what the marketing message actually promises.

7. Check the relationship between your claims and your evidence

Finding a claim is only half of the job. For every environmental claim that remains on your website, you should be able to identify the evidence that supports it. That evidence might include:

• Certification documents
• Lifecycle assessments
• Laboratory or testing results
• Product specifications
• Supplier documentation
• Recycled-content documentation
• Energy or emissions data
• Environmental performance assessments

The important thing is that the evidence needs to support the specific claim being made. A general sustainability report may contain useful information, but that does not necessarily mean it substantiates every environmental statement appearing on your website.

A useful internal test is simple: if someone from legal or compliance asked "Show me the evidence for this claim", could your marketing team quickly provide it? If the answer is no, the claim may need further review, even if the statement itself appears reasonable.

8. Don't forget images and design

One of the easiest things to overlook during a website audit is the visual side of environmental communication. EmpCo's definition of an environmental claim includes pictorial, graphic and symbolic representations, which means that an environmental impression can be created without explicitly saying "sustainable".

Think about a product page covered in green colours, leaves, forests, recycling symbols and imagery of nature. Even if the written copy is carefully worded, those elements can contribute to the overall impression consumers receive.

This does not mean that using the colour green or a picture of a tree automatically creates a prohibited environmental claim. Context matters. The important point is that marketing teams should assess the overall communication, rather than reviewing written copy in isolation.

9. Check claims about legal requirements

Another area worth checking is whether your website presents something as a special environmental advantage when it is actually a legal requirement. EmpCo prohibits presenting requirements imposed by law on all products within a relevant product category as a distinctive feature of the trader's offer.

For example, if every product in a particular category is legally required to meet a specific environmental standard, highlighting that compliance as though it were a voluntary sustainability advantage can give consumers a misleading impression about how your product compares with competitors.

Ask yourself:

"Is this genuinely an environmental advantage of our product, or is it something every product in this category is legally required to do?"

If it is the latter, your marketing team should reconsider how the information is presented.

10. Review the context, not just individual claims

One of the biggest mistakes in an EmpCo website audit is reviewing every sentence separately and assuming that compliant individual statements automatically result in compliant communication.

Consumers do not experience a website as a spreadsheet of individual claims. They see a product image, headline, badge, description, icons, sustainability information and other design elements at the same time. Those elements work together to create an overall impression.

This is why a proper website review should consider the full customer journey. Look at what a consumer sees when they arrive on a product page, what claims appear above the fold, which environmental benefits are highlighted and whether the evidence or qualification is visible at the point where the claim is made.

11. Make sure your claims stay accurate after changes

Website compliance is not a one-time exercise. Your products, suppliers, materials and marketing campaigns can change, and those changes can affect the validity of environmental claims.

For example, a product might originally use 80% recycled material and later change to 50%. If the website still says "made with 80% recycled material", the claim is no longer accurate. Similarly, an expired certification or changed supplier specification can affect whether an existing environmental statement remains supportable.

Marketing teams should therefore have a process for reviewing environmental claims when relevant information changes. This is particularly important for organisations with large product catalogues, where keeping hundreds or thousands of claims manually updated can become difficult.

The practical EmpCo website checklist

To confirm your website is EmpCo-compliant, make sure your team can answer "yes" to the following:

• Have we identified environmental claims across our entire website?
• Have we reviewed product pages, landing pages, blogs and downloadable content?
• Have we checked environmental labels, badges and symbols?
• Have we reviewed generic claims such as "eco-friendly", "green" and "sustainable"?
• Does the scope of each claim match the scope of the evidence?
• Have we reviewed carbon-neutral and other climate-related claims?
• Have we checked future environmental commitments?
• Can we identify the evidence supporting each claim?
• Have we reviewed images and other visual elements that may contribute to an environmental impression?
• Have we checked whether any environmental benefit is actually a legal requirement?
• Do we have a process for reviewing claims when products, suppliers or campaigns change?

If several of these questions are difficult to answer, that is a sign that your organisation may need a more structured approach to EmpCo compliance.

Why a manual website audit may not be enough

For a small website, manually reviewing every page may be realistic. For a large organisation with thousands of URLs, multiple brands and several markets, the process becomes considerably more difficult. Marketing teams need to find the claims, understand their context, locate the supporting evidence and coordinate remediation with legal and sustainability teams.

This is where an automated claims inventory can make the process more manageable. Instead of starting with a blank spreadsheet, businesses can use technology to identify potential environmental claims across their content and create a central overview of what needs to be reviewed.

At Gilbert, we developed the EMPCO Scanner specifically to help businesses with this process. The platform can scan websites and documents, identify environmental claims and assess them against relevant EmpCo requirements, helping teams move from discovery to assessment and remediation. This gives marketing, legal and sustainability teams a shared starting point for their compliance work.

The benefit is not simply finding claims faster. Once claims have been identified, teams can assign responsibility, connect supporting evidence, document decisions and revisit claims as content changes. That makes it easier to treat EmpCo compliance as an ongoing process rather than a one-time website clean-up.

Is your website EmpCo-compliant?

EmpCo compliance starts with knowing what your website is actually saying. Generic environmental claims, sustainability labels, carbon-related statements, future commitments and even visual elements can all contribute to the environmental impression created for consumers.

The most important question for marketing teams is therefore not simply "Have we removed the risky words?" It is "Can we substantiate the environmental impression our website creates?" That requires looking at claims in context, connecting them to evidence and putting a process in place to keep them accurate as your products and content change.

With the EmpCo rules applying since 27 September 2026, there is no transition period. Every week without a review leaves non-compliant claims exposed — start with the claims that need the most attention.