Certification schemes and third-party verification under EmpCo
Most defensible labels and claims under EmpCo pass through certification and independent verification. Article 2(r) sets four operational criteria; recognised Type I ecolabels unlock generic claims.
EmpCo makes recognised certification and independent verification the gateway for most sustainability labels and many environmental claims. Article 2(r) sets four operational criteria; recognised Type I ecolabels unlock the door to generic claims.
The four Article 2(r) criteria
- Open under transparent, fair and non-discriminatory terms to all traders willing and able to comply.
- Requirements developed in consultation with relevant experts and stakeholders.
- Non-compliance procedure including withdrawal or suspension of the label.
- Monitored by an independent third party whose competence and independence rest on international, Union or national standards.
The Commission's November 2025 FAQ adds that the scheme owner and the verifier should be legally separate entities. Recital 7 references ISO 17065 and Regulation (EC) 765/2008 accreditation mechanisms as benchmarks.
Recognised Type I ecolabels
For claims requiring "recognised excellent environmental performance" the qualifying schemes are: EU Ecolabel (Regulation 66/2010), recognised national or regional EN ISO 14024 Type I schemes — Nordic Swan, Blue Angel, Austrian Umweltzeichen, NF Environnement — and top-performance demonstrations under other EU law such as Class A under the Energy Labelling Regulation. The EU organic logo under Regulation 2018/848 functions as a public-authority scheme for organic claims.
Type I vs Type II vs Type III
- Type I (ISO 14024) — third-party multi-criteria certification. Gold standard under EmpCo.
- Type II (ISO 14021) — self-declared single-attribute claims. Permitted for narrow factual statements; insufficient for sustainability labels.
- Type III (ISO 14025) — Environmental Product Declarations (PEFCR / EN 15804). Useful as substantiation evidence, not as a label.
Verifying future claims
SBTi target validation is a common starting point but does not by itself satisfy EmpCo's recurring verification expectation. Most defensible programmes pair an SBTi-validated target with annual independent assurance (ISAE 3000 / ISAE 3410 for non-financial information; ISO 14064-3 for GHG) plus a published verifier report accessible to consumers.
Citations: Directive (EU) 2024/825 Article 2(r); Recital 7; ISO 14024, 14021, 14025, 17065; Regulation (EC) 765/2008; Commission DG JUST FAQ (Nov 2025).