EmpCo for FMCG and consumer goods
FMCG carries the largest aggregate exposure under EmpCo — millions of SKUs, dense packaging real estate, and a marketing tradition built on "natural", "pure" and "kinder to the planet".
FMCG carries the largest aggregate EmpCo exposure: millions of SKUs, dense packaging real estate, multilingual claims across 27 markets, retailer private labels and a marketing tradition built on "natural", "pure" and "kinder to the planet".
Food and beverages — words to retire
"Natural" sits on the Recital 9 banned list. "Plant-based" is acceptable as a factual claim (the product is plant-based) but risky as an environmental claim ("plant-based = better for the planet") without life-cycle substantiation. "Locally sourced" needs scope. "Carbon-neutral milk", "climate-neutral water", "CO₂ zero impact" — all banned under Annex I point 4c when based on offsetting. The UK ASA's Persil ruling (September 2022) showed that life-cycle-style claims ("kinder to our planet") require full LCA evidence, not selective metrics.
Household and personal care
"Eco", "ecological", "green", "biodegradable", "natural", "clean", "reef-safe" — almost all of these now require either (a) a recognised Type I ecolabel (EU Ecolabel, Nordic Swan, Blue Angel) or (b) reformulation as specific substantiated claims. France's DGCCRF announced strengthened cosmetic claims controls in 2023; expect application across the bloc.
Packaging interactions
FMCG is where EmpCo and the PPWR collide most often — "recyclable bottle", "100% recycled" (cap and label excluded), "compostable wrapper" are all dual-regulated. The Coca-Cola and Nestlé Waters 2023 commitments to specify "excluding cap and label" are now the template.
Future climate communications
Large FMCG net-zero pathways must be expressed in consumer-facing channels with the published implementation plan, time-bound milestones, independent verifier and accessible findings the directive demands. CSRD/ESRS E1 transition plans usually supply the substance; EmpCo requires the consumer-readable version with a clear URL on pack or in advertising.
An FMCG compliance playbook
- Global green-claims vocabulary policy (banned and conditionally permitted terms).
- Market-by-market specification rule (substantiation routes vary by local certification recognition).
- Pack artwork audit pipeline.
- CMS-level claim governance that prevents banned terms from being published.
- Quarterly recurring scan.
- Sign-off workflow across sustainability, legal, regulatory affairs and marketing.
Citations: UK ASA rulings (Innocent Drinks, Persil, Quorn, Oatly, AHDB); AGCM Ferrarelle and San Benedetto; BGH Katjes (27 June 2024); DGCCRF cosmetics guidance (2023); Directive (EU) 2024/825 Annex I; Regulation (EU) 2025/40 (PPWR).