EmpCo Directive — answers, explained
Plain-English help on EU Directive 2024/825: what's banned, what's required, and how to comply now that enforcement is live.
Most-read articles
What is the EmpCo Directive?
5 min readCPC 'old stock' Common Understanding
6 min readTimeline & key dates
4 min readGeneric environmental claims
6 min readCarbon neutral & offsetting
5 min readPenalties & enforcement
5 min readHow to comply (14 steps)
7 min readRecent enforcement cases
7 min readGreen claims governance
7 min read
Overview & scope
What the EmpCo Directive is, the dates that matter, and who has to comply.
What is the EmpCo Directive?
Plain-English explainer on EU Directive 2024/825 (EmpCo / ECGT): what it changes in the UCPD and CRD, why it was adopted, and how it fits with the Green Deal.
5 min readTimeline & key dates
Every key EmpCo date: OJ publication, entry into force, transposition deadline (27 March 2026), application date (27 September 2026), GARAN implementing act and the 2031 review.
4 min readWho does EmpCo apply to?
EmpCo scope explained: B2C, all sizes, every channel (packaging, web, social, influencers, marketplaces), with full extraterritorial reach for non-EU sellers marketing to EU consumers.
4 min readEmpCo vs Green Claims Directive
EmpCo prohibits unfair green claims; the proposed Green Claims Directive would have required ex-ante substantiation. Here is how the two relate in 2026.
5 min read
Prohibited & risky claims
The new blacklist additions plus deep dives on generic, carbon-neutral, label-based and future claims.
New prohibited practices
EmpCo adds ~10 new entries to UCPD Annex I — always-illegal misleading green claims and obsolescence practices. Full reference list with explanations.
6 min readGeneric environmental claims
How EmpCo defines an environmental claim, the 17+ generic green words at risk, and the two narrow paths to keep using them lawfully. Includes risky vs. compliant rewrites.
6 min readCarbon neutral & offsetting
EmpCo bans product-level carbon-neutral, climate-neutral and net-zero claims based on offsets. What you can still say, and how to switch to contribution language.
5 min readSustainability labels
Since 27 September 2026 only public-authority labels or third-party certification schemes meeting EmpCo's five criteria are allowed. Includes compliant vs. likely-non-compliant examples.
5 min readFuture performance claims
Net-zero and carbon-neutral-by targets are not banned outright — but EmpCo requires public, time-bound implementation plans with allocated resources and independent third-party verification.
4 min readSubstantiating environmental claims
A practical framework for substantiating environmental claims under the EmpCo Directive: evidence hierarchy, specificity, scope, relevance and governance.
6 min readPackaging claims
"Recyclable", "biodegradable" and "compostable" packaging claims face new constraints under EmpCo and the Packaging and Packaging Waste Regulation.
5 min readOffsetting claims after EmpCo
EmpCo bans offset-based neutrality claims at product level. Here is how to restructure offsetting communications into a defensible three-layer architecture.
5 min readCertification & verification
EmpCo elevates the role of certification schemes and independent verification. Here is how to assess your schemes and verifiers against the four Article 2(r) criteria.
6 min read
Product information duties
Durability, the GARAN label, software-update transparency, reparability and anti-obsolescence rules.
Durability & reparability (GARAN)
EmpCo's amendments to the Consumer Rights Directive: legal vs. commercial guarantee, the new GARAN harmonised label, software-update transparency and the reparability score.
6 min readObsolescence & software
EmpCo's Annex I points 23d–23j: planned obsolescence, deceptive software updates, false repairability, premature consumable prompts and non-original part disclosures.
5 min read
Enforcement & penalties
Who enforces EmpCo, how fines are calculated, and the role of private and collective redress.
Penalties & enforcement
EmpCo plugs into the UCPD enforcement regime — fines of at least 4% of annual turnover for widespread cross-border infringements (or at least €2 million where turnover data is unavailable), CPC Network sweeps, and collective redress under Directive 2020/1828.
5 min readRecent enforcement cases
KLM, TotalEnergies, H&M, Decathlon, DWS, Adidas, SHEIN — what the most recent EU greenwashing cases tell sustainability and compliance teams under EmpCo.
7 min readCPC 'old stock' Common Understanding
On 30 June 2026 the EU Consumer Protection Cooperation Network published a Common Understanding on how national authorities should enforce EmpCo against products, packaging and marketing produced before 27 September 2026.
6 min read
Practical guidance
Step-by-step compliance checks and answers to the questions brand and marketing teams ask most.
How to comply (14 steps)
A structured 14-step EmpCo compliance project: audit, categorise, substantiate, redesign, document, train and monitor — the rules have applied since 27 September 2026.
7 min readFAQs
Plain-language answers to 17 of the most common EmpCo questions — generic claims, carbon neutral, supplier labels, influencer content, B2B, SMEs, brand names and more.
8 min readGreen claims inventory
A step-by-step guide to building a green claims inventory across websites, packaging and documents — the foundation of every EmpCo compliance programme.
6 min readCSRD ↔ EmpCo alignment
CSRD governs sustainability reporting; EmpCo governs B2C green claims. Misalignment between the two is now a major compliance risk — here is how to close the gap.
5 min readGreen claims governance
A defensible green claims governance programme combines roles, processes and evidence. Here is what good looks like under the EmpCo Directive.
7 min read2026 compliance plan
A pragmatic catch-up plan for companies starting now that EmpCo applies since 27 September 2026, focused on what to do in each Member State and how to absorb national variations.
5 min readSell-through & existing stock
EmpCo grants no sell-through window. Since 27 September 2026, non-compliant green claims on existing stock are unlawful — even if produced earlier.
6 min read
Sector guidance
Where EmpCo lands hardest by industry — high-risk vocabulary and remediation patterns for fashion, FMCG and beyond.
Fashion & textiles
Fashion and textile brands carry the heaviest greenwashing enforcement record in Europe. Here is where EmpCo risk concentrates — and how to act.
6 min readFMCG & consumer goods
FMCG marketing relies on the exact green vocabulary EmpCo now bans. Here is how food, beverage, household and personal-care brands should act now.
6 min read
Reference & sources
Glossary of defined terms and the primary EU sources behind every rule on this site.
Glossary
Plain-English definitions of EmpCo's key terms inserted into the UCPD and CRD: trader, environmental claim, sustainability label, GARAN, reparability score and more.
5 min readSources & further reading
Primary EU sources behind EmpCo: EUR-Lex links, the directives it amends, plain-language commentaries and national enforcement signals.
3 min read
Frequently asked questions
CPC Network Common Understanding on EmpCo "old stock"
Six principles the EU's consumer protection authorities use to enforce EmpCo against products, packaging and marketing that pre-date 27 September 2026.