What Is the EmpCo Directive (EU 2024/825) and What Does It Mean for Businesses?

Environmental claims have become a standard part of how businesses communicate with consumers. Terms such as "sustainable", "eco-friendly", "climate-friendly" and "carbon neutral" appear across websites, product packaging, advertising campaigns and social media. At the same time, consumers and regulators are paying closer attention to whether these claims are accurate, specific and supported by evidence. This is where the Empowering Consumers for the Green Transition Directive (EU) 2024/825, better known as the EmpCo Directive, comes in.

For businesses selling to consumers in the European Union, EmpCo represents an important change in how environmental claims and sustainability-related communication need to be handled. The Directive strengthens existing consumer protection rules and introduces new restrictions on certain commercial practices that can mislead consumers about the environmental characteristics of products and services. The new rules have applied since 27 September 2026 — every claim you publish today is already exposed.

What is the EmpCo Directive?

The EmpCo Directive is an EU directive designed to improve consumer protection during the transition towards more sustainable consumption. It amends the existing Unfair Commercial Practices Directive and Consumer Rights Directive to give consumers better information and protection against misleading environmental claims and other sustainability-related marketing practices.

The Directive was adopted in February 2024, and Member States had until 27 March 2026 to transpose the rules into national legislation. Since 27 September 2026, the requirements apply to businesses operating in the EU. Although the Directive is focused on consumer protection, its practical impact is felt across many parts of a business, particularly marketing, legal, sustainability, product and compliance teams.

The underlying principle is relatively straightforward: consumers should be able to make informed purchasing decisions based on reliable information. A business should not give the impression that a product or company has environmental benefits that cannot be properly substantiated. For businesses, this means environmental claims need to be considered not only from a marketing perspective, but also from the perspective of accuracy, evidence and legal compliance.

Why has the EU introduced EmpCo?

The growth of sustainability marketing has created a difficult situation for consumers. Businesses may communicate genuine environmental improvements, but consumers often have no easy way of determining whether a broad claim actually means anything measurable. A product described as "green" or "sustainable", for example, can create a strong environmental impression without explaining which aspect of the product is better for the environment or what evidence supports that statement.

The EmpCo Directive is part of a broader EU effort to make sustainability claims more reliable and tackle greenwashing. The goal is not to prevent companies from communicating about their environmental performance. Instead, the rules are intended to make those communications more transparent and meaningful, so consumers can better understand the environmental characteristics of the products they are considering.

This creates an important distinction for marketers. The question is no longer simply whether a sustainability message sounds convincing or fits the brand. Businesses increasingly need to ask whether the message creates an environmental impression that can be supported with reliable evidence and whether the wording complies with the applicable rules.

What changes under the EmpCo Directive?

One of the most important changes concerns the way businesses use environmental claims in commercial communication. The Directive introduces new practices to the list of commercial practices that are considered unfair and strengthens existing rules around misleading actions and omissions. This means certain types of environmental communication can create compliance risks even when a business did not intend to mislead consumers.

The rules cover several areas that are particularly relevant to modern marketing. These include generic environmental claims, sustainability labels, claims relating to future environmental performance and certain claims about climate impact or greenhouse gas emissions. Businesses therefore need to look beyond individual words and consider the overall environmental impression created by their communication.

Environmental claims also rarely exist in isolation. A product page might contain a headline saying "sustainable", a green symbol next to the product name, information about recycled materials further down the page and a carbon-related statement in the product description. Each element contributes to the impression a consumer receives, which means reviewing individual pieces of copy may not provide a complete picture of the compliance risk.

Generic environmental claims require particular attention

Broad environmental claims are one of the areas businesses should review carefully now that the rules apply. Terms such as "green", "eco-friendly", "environmentally friendly" and "sustainable" can communicate a broad environmental benefit without explaining what that benefit actually consists of. Under the new rules, businesses cannot simply rely on positive environmental language without considering whether the claim is sufficiently specific and supported.

Consider a statement such as:

"Our most sustainable product yet."

On the surface, the claim sounds straightforward. But from a compliance perspective, it raises several questions. What makes the product more sustainable, compared with what, and what evidence supports the statement?

A legal or compliance team may need to ask:

• What does "sustainable" mean in this specific context?
• Compared with which product or benchmark?
• What evidence supports the claim?
• Where is that evidence stored?
• Does the evidence apply to the entire product or only part of it?
• Is the claim still accurate after a product or supplier change?
• Is the same wording being used elsewhere?

This illustrates why EmpCo compliance can quickly become more complicated than reviewing individual pieces of marketing copy. A single claim can involve marketing, legal, sustainability, product teams and suppliers, while the supporting evidence may be spread across different systems or documents.

The practical implication for marketing teams is not that every environmental claim needs to disappear. Instead, businesses should look at whether broad claims can be replaced by more specific statements that explain the relevant environmental characteristic. A claim about a defined percentage of recycled material, for example, provides considerably more information than simply describing a product as "eco-friendly", provided the specific claim itself can be substantiated.

Sustainability labels and certifications

EmpCo also introduces stricter rules around environmental and sustainability labels. Consumers can easily interpret a green logo, badge or certification-style symbol as an indication that a product has been independently assessed or meets specific sustainability criteria. Businesses therefore need to consider not only the wording they use, but also the symbols and labels that form part of their marketing communication.

The Directive places requirements on sustainability labelling schemes and addresses situations where businesses create or use labels that can give consumers a misleading impression of environmental credentials. A company cannot simply design its own green badge and use it in a way that suggests independent certification if that impression is not justified.

For businesses, this means a review should include more than written claims. It can also be useful to identify the environmental labels and symbols currently used across products and marketing materials, then establish what each one means, who operates the underlying scheme and what evidence supports its use.

Carbon-neutral and climate claims

Claims relating to carbon neutrality and climate impact deserve particular attention because they can create a broad impression about the environmental impact of a product, service or organisation. Statements such as "carbon neutral" or "climate neutral" can suggest to consumers that an activity has little or no negative climate impact. Businesses therefore need to carefully assess both the wording of these claims and the evidence behind them.

This becomes especially important when claims rely on carbon offsetting or similar mechanisms. The fact that emissions are compensated does not automatically mean that a broad environmental claim is appropriate in every context. Businesses need to understand exactly what their claim communicates and whether the evidence and methodology behind it support that message.

Future environmental claims also require attention. A statement such as "carbon neutral by 2030" communicates a commitment about future environmental performance, which means businesses need to be able to demonstrate that the claim is based on a clear, realistic and verifiable plan. This is another area where marketing language and underlying sustainability data need to work together rather than being treated as separate processes.

EmpCo is not just a marketing issue

Although environmental claims are often created by marketing teams, EmpCo compliance cannot realistically sit with marketing alone. The evidence needed to support a claim may come from sustainability teams, product teams, suppliers or external certification bodies, while legal and compliance teams may be responsible for assessing whether the claim can be used.

This creates a practical challenge for organisations with large product catalogues or multiple brands. A single claim may appear on a website, in paid advertising, on packaging and in a product catalogue, while the evidence supporting that claim may be stored somewhere else entirely. If one part of the claim changes, it can also become necessary to review every location where that claim is being used.

A marketer might therefore write:

"Made with sustainable materials."

The statement may seem harmless, but a compliance review could lead to questions about the materials, the definition of "sustainable", the supporting evidence and the scope of the claim. If the materials or suppliers change six months later, the business may also need to establish whether the original claim is still accurate.

This is why businesses should start treating environmental claims as assets that need to be managed throughout their lifecycle. It should be possible to identify where a claim is being used, understand who is responsible for it, access the evidence behind it and determine what happens when the claim is changed or challenged.

What should businesses do now?

The first step is to understand the scale of the problem. Before deciding which claims need to be changed, businesses need to know where their environmental claims currently appear. That means looking beyond the main sustainability page and reviewing product pages, packaging, advertising, social media, PDFs, catalogues and other customer-facing materials.

Depending on the size and complexity of the organisation, this review may cover a significant amount of content. At a minimum, businesses should consider areas such as:

• Website and product pages
• Paid advertising and campaign materials
• Social media content
• Packaging and product labels
• Product catalogues and brochures
• Sustainability reports and other documents
• Environmental labels, badges and symbols

Once the claims have been identified, businesses can assess which ones require further attention. Broad environmental claims, sustainability labels, carbon-related statements and future environmental commitments may require more detailed review, particularly where the supporting evidence is unclear or difficult to locate.

The goal should not simply be to remove as many environmental claims as possible. In many cases, the better approach is to make a claim more specific, strengthen the evidence behind it or clarify exactly what environmental characteristic is being communicated. This allows businesses to continue communicating genuine environmental improvements while reducing unnecessary compliance risk.

Building an evidence trail

Identifying claims is only one part of the process. Businesses also need to know what evidence sits behind those claims and whether that evidence is still valid. Depending on the type of environmental statement, relevant evidence could include certifications, lifecycle assessments, laboratory results, technical specifications, supplier documentation or other supporting information.

Keeping that evidence accessible is particularly important when several teams are involved. If marketing owns the claim, sustainability owns the underlying data and legal owns the approval process, teams need a shared way of connecting those pieces of information. Otherwise, a business may technically have the evidence but still struggle to demonstrate why a particular claim is justified.

This becomes even more important when claims change over time. A supplier may change a material, a certification may expire or a product specification may be updated. A claim that was accurate when it was originally approved can therefore become inaccurate later, making ongoing monitoring an important part of EmpCo compliance.

Why manual compliance becomes difficult at scale

For a small organisation with a limited number of products and marketing channels, reviewing environmental claims manually may be manageable. For larger businesses, the situation is very different. Thousands of product pages, multiple websites, advertising campaigns, documents and packaging variations can make it difficult to establish exactly where environmental claims are being used.

The challenge becomes even greater when evidence and responsibility are spread across different teams. A marketer may know where a claim is being used, while a sustainability specialist has the supporting data and a legal team is responsible for the final assessment. Without a central process, information can quickly become fragmented, making it difficult to understand the organisation's current compliance position.

This is where technology can make the process more manageable. Rather than relying entirely on manual searches and spreadsheets, businesses can use technology to identify claims, organise findings, assess potential risks and create a central workflow for remediation and evidence management.

How Gilbert helps businesses comply with EmpCo

At Gilbert, we developed the EMPCO Scanner to help businesses identify and manage environmental claims under the new requirements. The platform can scan websites and documents to identify environmental claims and assess them against the relevant EmpCo requirements, giving businesses a clearer view of where potential risks exist.

Once claims have been identified, teams can review their risk, assign claims to the appropriate people and connect them to supporting evidence. This creates a more structured workflow between marketing, legal, sustainability and compliance teams, rather than leaving each department to manage its part of the process separately.

The process can be thought of as four connected stages:

Identify → Assess → Remediate → Document

First, businesses identify the environmental claims they are making. They can then assess the claims against the relevant requirements, make changes where necessary and document the evidence and decisions behind those changes. This provides a more structured approach than conducting a one-off manual audit.

The platform also supports ongoing monitoring, allowing businesses to keep track of claims as their content and products change. That matters because EmpCo compliance does not end once an initial review is complete. New campaigns, new products and changes to existing claims can all create new compliance questions.

EmpCo is ultimately about making environmental claims more trustworthy

The EmpCo Directive represents a significant change in the way businesses need to think about environmental communication. Sustainability claims are no longer simply a creative consideration for marketing teams. They need to be connected to evidence, assessed against regulatory requirements and managed as part of an ongoing process.

For businesses, the most useful question is therefore not simply "Can we use this claim?" but "Can we clearly explain what this claim means, support it with evidence and demonstrate why it is appropriate?" Answering that question across every relevant product, campaign and communication channel is the real challenge of EmpCo compliance.

The good news is that complying with EmpCo does not mean removing sustainability from your marketing. It means making environmental communication more precise, transparent and defensible. Businesses that establish a clear process for identifying, reviewing and substantiating their claims can continue communicating their environmental progress while meeting the rules that are already in force.

With the rules applying since 27 September 2026, there is no transition period. By identifying their environmental claims and understanding the evidence behind them now, organisations can fix the riskiest claims faster.