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EU green claims rules: what changes on September 27, 2026

On 27 September 2026, the Empowering Consumers for the Green Transition Directive — Directive (EU) 2024/825, known as EmpCo — becomes enforceable across all EU Member States. From that date, environmental claims made to EU consumers are subject to strict new rules. There is no transition period. Claims that were acceptable on September 26 may be unlawful on September 27.

6 MIN READ · UPDATED 30 AUGUST 2026 · REVIEWED BY THE REGONANCE EDITORIAL TEAM

On 27 September 2026, the Empowering Consumers for the Green Transition Directive — Directive (EU) 2024/825, known as EmpCo — becomes enforceable across all EU Member States. From that date, environmental claims made to EU consumers are subject to strict new rules. There is no transition period. Claims that were acceptable on September 26 may be unlawful on September 27.

If you sell products in the EU and make any environmental or sustainability claims — on your packaging, your product listings, your website, or your advertising — this directive applies to you.

This guide explains what EmpCo requires, what types of claims are affected, and what to review in your product listings before the deadline.


What EmpCo is

EmpCo amends two existing pieces of EU consumer protection law: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). It does not create a new standalone regulation — it strengthens the existing framework by adding specific rules about environmental claims.

The directive was adopted in February 2024 and published in the Official Journal on 6 March 2024. Member States were required to transpose it into national law by 27 March 2026. The rules become binding for businesses on 27 September 2026.

EmpCo is sometimes confused with the Green Claims Directive — a separate proposal that was withdrawn by the European Commission in June 2025. EmpCo is the binding law. The Green Claims Directive is not. If you have been tracking "EU green claims regulation," EmpCo is the one that matters.


What changes on September 27

Generic environmental claims are prohibited without substantiation

From September 27, businesses can no longer make general, vague environmental claims such as:

  • "eco-friendly"
  • "green"
  • "environmentally friendly"
  • "sustainable"
  • "climate-friendly"
  • "good for the planet"
  • "conscious"
  • "responsible"

unless the claim is substantiated by recognised, excellent environmental performance relevant to the claim. In practice, a generic claim like "eco-friendly" is effectively banned because it refers to the product's overall environmental impact — which is almost impossible to substantiate comprehensively.

Offset-based carbon neutrality claims are banned

EmpCo explicitly prohibits claims of neutral, reduced, or positive environmental impact when they rely on greenhouse gas offsetting outside the product's own value chain. This means:

  • "carbon neutral" — banned if based on purchased carbon credits
  • "climate neutral" — banned if based on offsetting
  • "CO2 compensated" — banned if based on offsetting
  • "net zero" — banned if based on offsetting rather than actual emissions reductions within the value chain

This is one of the most commercially significant provisions. Many brands currently use "carbon neutral" claims backed by offset certificates. From September 27, these claims are unlawful in the EU unless the neutrality is achieved through actual reductions in the product's value chain — not through purchased credits.

Future environmental commitments need backing

Claims about future environmental performance — such as "carbon neutral by 2030" or "100% recyclable packaging by 2028" — can only be made if they are supported by:

  • clear, objective, and publicly available commitments;
  • a detailed implementation plan with measurable and time-bound targets;
  • regular independent third-party verification.

A vague pledge without a published plan and verification mechanism is not compliant.

Unrecognised eco-labels and self-certifications are banned

Sustainability labels displayed on products or listings must be based on a certification scheme or established by public authorities. Self-created labels, logos, or badges that suggest environmental credentials without an underlying recognised scheme are prohibited.

This affects brands that have created their own "green" badges, sustainability scores, or environmental certification marks. Unless the label corresponds to a recognised certification scheme, it cannot be used.

Misleading durability and repairability claims are prohibited

EmpCo adds new unfair commercial practices related to product durability:

  • claiming a product has a certain durability (in terms of time or intensity of use) when it does not;
  • presenting a product as repairable when it is not;
  • failing to inform consumers that a product is designed to limit its functionality when using non-original consumables, spare parts, or accessories.

Which claims are still allowed

EmpCo does not ban all environmental communication. It bans vague, unsubstantiated, and misleading claims. The following types of claims remain permissible:

Specific, substantiated claims about a single measurable attribute. For example: "This packaging contains 80% post-consumer recycled plastic" — if true and verifiable. The claim is specific (names one attribute), measurable (80%), and verifiable (test data exists).

Claims based on recognised EU or Member State certification schemes. For example: "EU Ecolabel certified," "FSC certified," "GOTS certified." These are backed by independent, publicly accessible certification standards.

Factual statements about material composition or product characteristics. For example: "Made from organic cotton" (if certified), "BPA-free" (if tested), "Compostable according to EN 13432" (if certified).

The distinction is between vague endorsement ("eco-friendly") and specific fact ("80% recycled content, verified by [scheme]"). EmpCo rewards specificity and penalises vagueness.


The penalties

EmpCo does not set harmonised EU-wide fines — enforcement is through national consumer protection authorities, and penalties vary by Member State. However, the amended Unfair Commercial Practices Directive allows for fines of up to 4% of annual turnover for widespread infringements. Individual Member States may set higher thresholds.

Beyond fines, enforcement can include:

  • orders to withdraw or modify advertising;
  • product listing modifications required by marketplaces;
  • injunctions against specific claims;
  • publication of enforcement decisions (reputational impact).

Marketplace enforcement is also likely. If Amazon, Shopify, or other platforms implement EmpCo-related listing checks — as they have done with GPSR — non-compliant claims could trigger listing suppression.


What to do before September 27

1. Audit every environmental claim in your product listings

Search your product titles, descriptions, bullet points, images, and A+ content for any environmental or sustainability language. Common terms to flag: eco, green, sustainable, natural, organic (if not certified), carbon neutral, climate neutral, recyclable (if not verified), biodegradable, compostable, plant-based, responsible, conscious.

2. Remove or substantiate generic claims

For each flagged claim, decide: can you substantiate it with specific, verifiable evidence? If yes, rewrite the claim to be specific. If no, remove it.

Before: "Our eco-friendly packaging is good for the planet." After: "Our packaging is made from 85% post-consumer recycled cardboard, certified by [scheme]."

Before: "Carbon neutral product." After: Remove entirely, unless neutrality is achieved through value-chain reductions (not offsets).

3. Check your sustainability labels and badges

If you display any self-created sustainability badge, logo, or score on your products or listings, verify that it corresponds to a recognised certification scheme. If it does not, remove it.

4. Review future-tense environmental commitments

If your listing or website says "we aim to be carbon neutral by 2030" or similar, verify that you have a published implementation plan with measurable targets and independent verification. If you do not, remove the claim or add the required backing.

5. Use the Regonance EmpCo Checker

Regonance offers a free EmpCo checker that scans your product URL or pasted marketing copy and flags environmental claims that may breach the directive. It identifies generic eco-claims, offset-based carbon neutrality language, unrecognised labels, and future commitments without substantiation.

Check your product claims now → free, no account required


How Regonance helps

Regonance scans your product listings and marketing copy against EmpCo requirements, flagging claims that risk non-compliance. Each finding is traced to the specific EmpCo provision it engages, scored by risk level, and accompanied by a recommended revision. The platform covers EmpCo alongside GPSR, PPWR, DPP, and other EU mandates in one workspace.

Start free workspace


Educational information only. Not legal advice. EmpCo is a directive — national transposition may vary by Member State. The European Commission FAQ (updated May 2026) provides non-binding interpretation guidance. Validate scope with a qualified advisor.

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Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.