EmpCo glossary
EmpCo introduces or relies on a tightly worded set of defined terms — mostly inserted into Article 2 of the UCPD and Article 2 of the CRD. Plain-English versions follow.
5 min readUpdated 2026-05-16
Summary
EmpCo introduces or relies on a tightly worded set of defined terms — mostly inserted into Article 2 of the UCPD and Article 2 of the CRD. Plain-English versions follow.
- Trader
- Any natural or legal person — public or private — acting for purposes relating to their trade, business, craft or profession. Covers sellers, manufacturers, importers, distributors, marketplaces, service providers, SMEs, freelancers, and ad agencies.
- Consumer / Average consumer
- A consumer is any natural person acting outside their trade or profession. The average consumer is the EU benchmark: reasonably well-informed, observant and circumspect. Where a practice targets a group (e.g. children), the test shifts to the average member of that group.
- Commercial practice
- Any act, omission, conduct, representation or commercial communication directly connected with the promotion, sale or supply of a product to consumers. Covers TV ads, packaging, online copy, email, and influencer posts.
- Environmental claim (UCPD 2(o))
- Any voluntary marketing message — words, pictures, logos, colours, brand or product names — saying or implying a product, brand or trader has a positive or zero environmental impact, is less damaging than alternatives, or has improved over time. Mandatory legal labels are excluded.
- Generic environmental claim (UCPD 2(p))
- Vague green talk in writing, speech or audiovisual media without on-the-spot specifics — e.g. "eco-friendly", "green", "natural", "climate friendly", "biodegradable".
- Sustainability label (UCPD 2(q))
- Any voluntary trust mark or quality mark — public or private — that promotes a product or business by reference to environmental or social characteristics.
- Certification scheme (UCPD 2(r))
- A third-party verification scheme meeting all five criteria: open, stakeholder-developed, non-compliance procedures, independent monitoring, public terms.
- Recognised excellent environmental performance (UCPD 2(s))
- EU Ecolabel, recognised national/regional ISO 14024 Type I ecolabels, or top class of an EU label such as the Energy Label. The performance must be relevant to the claim.
- Durability (CRD)
- The ability of goods to maintain their required functions and performance through normal use.
- Reparability score (CRD 2(14d))
- A score expressing the capacity of a good to be repaired, based on EU-harmonised methodology. Mandatory for smartphones and tablets since 20 June 2025.
- Software update (CRD 2(14e))
- A free update — including security update — necessary to keep goods with digital elements in conformity under Directives 2019/770 and 2019/771.
- Commercial guarantee of durability (CRD 2(14a))
- A producer's voluntary promise (beyond the 2-year legal guarantee) that the product will keep working for a stated longer period. The GARAN label flags products with a guarantee of more than two years.
- Producer
- The manufacturer, the importer into the EU, or any person presenting themselves as a producer by placing their name or trademark on the goods. The producer — not necessarily the seller — issues the commercial guarantee of durability.