What is EmpCo? The EU's anti-greenwashing law, in plain English

If you sell consumer products into the EU and your marketing uses the words "eco", "green", "sustainable", "carbon neutral", "natural", "climate-friendly" or anything in that family, the Empowering Consumers for the Green Transition Directive — Directive (EU) 2024/825, known as EmpCo — is the law you need to plan against. It is the EU's enforceable anti-greenwashing regime, and enforcement begins 27 September 2026.

EmpCo is short, direct, and surgically aimed at marketing language. This guide explains what it changes, who is in scope, the six banned practices, and what a defensible baseline looks like for a brand in 2026.

The framing correction nobody made loudly enough

In June 2025 the European Commission withdrew the standalone Green Claims Directive (the March 2023 proposal that would have required mandatory third-party pre-verification and full life-cycle substantiation). It is not law. It is not coming back in that form.

The law that is in force is EmpCo — adopted February 2024, in force since 26 March 2024, transposition deadline 27 March 2026, enforcement from 27 September 2026. It works by amending the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). Specific marketing practices are added to the UCPD "blacklist" of practices banned outright — no case-by-case test, no balancing exercise, no defense of "reasonable consumer would have understood".

If your remediation plan is built around the withdrawn proposal, it is built around the wrong rules.

What EmpCo actually requires

EmpCo is a claims and marketing-text regulation, not a physical-product regulation. It does not care what your product is made of in isolation — it cares about the language you use to sell it. The assessment input is the product page, the packaging copy, the social ad, the sustainability section of your website, the influencer brief. Substantiation evidence sits behind those claims; the absence of evidence is itself a violation.

Around that core, the directive adds three operational duties:

• Banned practices (UCPD Annex I additions) — see the six categories in the next section. Banned means banned; there is no balancing test.
• Substantiation requirement — where a claim is not on the banned list, the trader must hold demonstrable, recognised, and verifiable evidence backing the claim. The burden of proof is on the trader.
• Durability and reparability information at point of sale — where relevant, consumers must be given clear information on the expected lifetime, repairability, availability of spare parts, software-update support and any negative impact of those updates. This is a positive disclosure duty, not just a "don't lie" duty.

The six banned practices

The UCPD additions cover six specific patterns. If your marketing matches one, it is banned with no defence:

1. Generic environmental claims without substantiation. "Eco-friendly", "green", "environmentally friendly", "climate friendly", "biodegradable", "eco-conscious", "natural" used without demonstrated, recognised and verifiable excellent environmental performance. Generic terms that imply environmental superiority but cannot point to specific, verifiable evidence are out.
2. Offset-based product-level carbon claims. "Carbon neutral", "climate neutral", "net zero", "CO2-positive" applied to a product, based on offsetting rather than actual value-chain emissions reductions. Only claims based on genuine, in-supply-chain emission reductions are permitted. Company-level statements are not directly banned by this rule, but remain exposed to the general unfair-practices regime if misleading.
3. Sustainability labels not backed by a recognised certification scheme. Self-created eco-badges, unverified seals, and labels with no identifiable certification scheme behind them are banned. Examples of recognised schemes: EU Ecolabel, EU Organic, FSC, GOTS, OEKO-TEX, Cradle to Cradle. Your own "Eco Choice" badge with no third-party scheme behind it: banned.
4. Future environmental performance claims without a credible plan. "Climate neutral by 2030", "100% recycled material by 2027", "carbon-positive by 2035" are banned unless backed by clear, objective, publicly available and independently verified commitments set out in a detailed, realistic implementation plan with measurable, time-bound targets. A board slide is not a plan.
5. Advertising legally-required attributes as distinctive features. Marketing something as a unique selling point when it is already legally mandatory for every product in the category — for example, "free of [substance already EU-banned]". This catches a lot of personal-care and cleaning copy.
6. Missing durability and reparability information. Where relevant to the consumer's purchase decision, traders must give clear information on the product's expected lifetime, repairability index (where one applies), availability of spare parts and repair services, software-update duration, and any negative impact of those updates on the product.

Who is in scope

EmpCo captures every trader making business-to-consumer environmental, ethical or sustainability claims that reach EU consumers. That includes:

• Brand-owners selling under their own name in the EU 27.
• Importers and EU-established distributors.
• Non-EU sellers whose claims reach EU consumers via own-site, marketplace, or paid distribution — the directive attaches to the claim and the consumer, not to your country of incorporation.
• Online marketplaces — explicitly named as responsible actors; expected to act on flagged listings.
• Influencers and affiliates acting on behalf of brands — the brand carries primary liability, but the influencer may share it.

Exempt: micro-enterprises (fewer than 10 employees AND under €2 million annual turnover) from most requirements. Some national transpositions extend transition periods to other SMEs — check per country.

The minimum viable baseline for 2026

A defensible EmpCo posture has five elements you can stand up before September 2026:

1. A complete claims inventory. Every consumer-facing environmental, ethical or sustainability claim across product pages, packaging, ads, social, influencer briefs, sustainability pages, and corporate copy. You cannot fix what you cannot see.
2. A banned-practice classification per claim. For each claim, identify which (if any) of the six banned categories it triggers, and the severity.
3. An evidence file behind every retained claim. Source documents, certification numbers, scheme references, lab reports, or supplier attestations. The absence of evidence IS the violation.
4. A durability and reparability disclosure standard for every product where the consumer would reasonably expect it (electronics, appliances, furniture, footwear).
5. A monitoring process — new copy, new SKUs, and seasonal campaigns all need to pass the same filter. EmpCo is not a one-off audit; it is a permanent guardrail on marketing.

How Regonance helps

Regonance runs an AI claims scan over your product URLs, marketing copy, packaging text and sustainability pages, classifies every claim against the six banned-practice categories with severity and a plain-language remediation (substantiate / qualify / replace / remove), and captures the evidence file behind your retained claims. The free EmpCo checker handles single-page checks with no signup; the full per-claim assessment with evidence capture is on Pro and Agency plans.

What to do this quarter

• Inventory every consumer-facing environmental or sustainability claim across all surfaces.
• Identify and remove or substantiate the obvious banned-practice hits — "eco-friendly", offset-based "carbon neutral", self-made eco-badges.
• For each future commitment ("climate neutral by 2030"), assemble the verifiable implementation plan or qualify the claim down.
• Add durability and reparability information at point of sale for in-scope products.
• Brief marketing, ecommerce, social, and the agency network on the new guardrails before the next campaign goes out.

Glossary

EmpCo. Empowering Consumers for the Green Transition Directive, Directive (EU) 2024/825.

UCPD. Unfair Commercial Practices Directive (2005/29/EC) — EmpCo works by amending this and the Consumer Rights Directive.

Banned practice. A practice listed in UCPD Annex I as banned outright, with no case-by-case balancing test.

Recognised certification scheme. A third-party scheme established by a public authority or an independent, transparent body — e.g. EU Ecolabel, EU Organic, FSC, GOTS, OEKO-TEX.

Representative Actions Directive. Directive (EU) 2020/1828, enabling consumer-NGO class actions for breaches of EU consumer law including EmpCo.

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Educational information, not legal advice. Validate scope and obligations with a qualified advisor before acting; consult the consolidated text of Directive (EU) 2024/825 on EUR-Lex for the authoritative legal source.