Gilbert

    Gilbert EmpCo — AI compliance scanner for EU green claims (Directive 2024/825)

    EmpCo Directive

    The EU has changed how green claims work. Here's what that means for you now.

    Directive 2024/825 — the Empowering Consumers Directive — has tightened the rules on environmental marketing across all EU member states. EmpCo has been enforced since 27 September 2026. Every claim you publish today must comply.

    No time to do it yourself? We handle EMPCO for you.

    See the EMPCO Service
    Knowledge base

    Read the full EmpCo guide — articles, case law, and rewrite playbooks.

    Everything compliance, marketing, and legal teams need to interpret Directive 2024/825 now that enforcement is live.

    What EmpCo is

    A directive that bans vague, unsubstantiated, and misleading environmental claims.

    EmpCo amends the Unfair Commercial Practices Directive (2005/29/EC) by adding specific prohibitions against greenwashing. It targets the language companies use in marketing, packaging, and public communications.

    Four categories of claims are now explicitly regulated:

    Generic claims
    "Eco-friendly", "green", "sustainable" without proof
    Offsetting claims
    Carbon-neutral via credits alone — now prohibited
    Single-aspect claims
    Highlighting one green trait while hiding harm
    Future promises
    "Net-zero by 2040" without a concrete, verifiable plan
    Why this matters

    Real enforcement, real consequences.

    Fines of at least 4% of annual turnover for widespread cross-border infringements (or at least €2 million where turnover data is unavailable)
    Consumer organisations can file collective actions
    National regulators gain injunction powers
    Reputational exposure through public enforcement registers
    Typical exposure pattern
    Homepage hero claimsHigh Risk
    Product packaging copyMedium Risk
    ESG report languageMedium Risk
    Paid ad campaignsHigh Risk

    Why real change is happening

    EmpCo doesn't just add rules — it changes the enforcement landscape across four dimensions:

    Marketing teams
    Generic sustainability language on landing pages, social ads, and packaging now carries legal risk.
    Product teams
    Labels and PDPs that reference environmental benefits need substantiation or face removal orders.
    Legal & compliance
    Internal review processes must now include claim-level evidence mapping — not just sign-off.
    Old content
    Archived pages and PDFs still live on Google. Regulators don't distinguish current from legacy.
    Why Gilbert exists

    Built to make EmpCo compliance practical, not theoretical.

    Gilbert doesn't just flag problems — it helps teams fix them. Every scan produces structured, actionable output: risk scores, legal references, and rewrite suggestions.

    Scan
    Crawl websites, documents, and product pages for environmental claims.
    Evaluate
    AI-assisted risk scoring against EmpCo criteria and EU case law.
    Remediate
    Actionable rewrites and evidence checklists for every flagged claim.

    "We built Gilbert because compliance teams deserve software that's as rigorous as the law — and as usable as the tools they already love."

    The threat is wider than you think

    It's not just regulators. NGOs, consumers, and competitors are watching too.

    NGO litigation
    NGOs across the EU are preparing test cases under EmpCo. Environmental organisations now have explicit standing to file collective actions against misleading green claims.
    Consumer disputes
    Consumers can use EmpCo as grounds in sales disputes — if a product was marketed with unsubstantiated environmental claims, buyers can challenge the sale and seek remedies.
    The dossier requirement
    Making a truthful claim isn't enough. Under EmpCo, every environmental claim must be backed by a pre-prepared substantiation dossier with methodology, data sources, and third-party verification. No dossier = non-compliant.
    New

    EMPCO Service

    Don’t want another system to operate? We’ll handle EmpCo for you.

    We check your websites, documents and packaging, draft every correction, and follow each point through to closure. Your team only needs to approve.

    See how the service works

    Example · closure report

    “100% eco-friendly packaging”

    Rewritten · closed

    Red

    “Climate neutral company”

    Removed · closed

    Red

    “Sustainably sourced ingredients”

    Evidence filed · closed

    Amber

    “Green energy for our production”

    With your team

    Amber

    Every point tracked to closure

    FAQ

    Frequently asked questions

    Knowledge base

    Read the full EmpCo guide — articles, case law, and rewrite playbooks.

    Everything compliance, marketing, and legal teams need to interpret Directive 2024/825 now that enforcement is live.