How to comply with EmpCo: a 14-step plan
Enforcement is live since 27 September 2026 — treat compliance as a structured 14-step project: audit, categorise, substantiate, redesign, document, train, monitor.
7 min readUpdated 2026-05-16
Summary
Enforcement is live since 27 September 2026 — treat compliance as a structured 14-step project: audit, categorise, substantiate, redesign, document, train, monitor.
- Audit every customer-facing claim. Single inventory across packaging, websites, marketplaces, paid ads, social, influencers, email, in-store POS, brochures, press, brand/product names, and reused sustainability-report extracts.
- Categorise each claim: generic; substantiated; future/aspirational; offset-based; sustainability labels; durability/repair/software statements.
- Gather substantiation evidence. LCA per ISO 14040/14044 or PEF; certifications and audit reports; methodology, scope, boundaries; supplier declarations. Rule of thumb: if you can't hand a regulator a file in 24 hours, you can't defend the claim.
- Remove or rewrite generic green claims. Strike "eco-friendly", "green", "responsible", "kind to nature", "planet-positive", "sustainable" unless backed by recognised excellent environmental performance.
- Review every sustainability label. Drop self-declared "green range" badges. Keep only EU public-authority labels or schemes meeting all five EmpCo criteria.
- Stop offset-based carbon-neutrality claims. Switch to contribution-based language.
- Validate future commitments. Publish a detailed implementation plan with measurable interim targets, allocated resources, and independent third-party verification.
- Update product pages with mandatory CRD information. Legal-guarantee notice; GARAN where applicable; software-update support period; reparability score; spare-part availability and pricing; repair manual; restrictions.
- Engage suppliers. Request label evidence in writing; update purchase contracts to require ongoing substantiation, indemnities and certification-lapse notification.
- Train teams and update workflows. Mandatory training for marketing, copywriters, designers, social/influencer, e-commerce, PR, sales. Build a legal+sustainability sign-off gate into creative approvals.
- Document everything. Central claims dossier linking each live claim to evidence, approver, expiry/review date and verification source.
- Monitor national transpositions and case law. Some Member States may apply rules to B2B; comply with the strictest applicable standard.
- Adopt conservative defaults. When in doubt, drop the claim. But beware "greenhushing" — ESPR, Right to Repair, and PPWR still mandate disclosures.
- Get compliant now. The 27 September 2026 application date has passed — every day with non-compliant packaging, ads, or listings is exposure. There is no grandfather clause.