EmpCo Directive to combat greenwashing

What is the EmpCo Directive?

Environmental claims, such as “sustainable”, “climate-neutral”, “environmentally friendly”, “green” or “eco”, are all around us. However, not every claim is clear or understandable to consumers. It often remains unclear exactly what an environmental benefit refers to, whether it is substantiated or whether it relates only to an individual aspect of a product or only to the packaging.

Empowering Consumers Directive

The ‘EU directive as regards empowering consumers for the green transition through better protection against unfair practices and through better information’ ((EU) 2024/825) amends and supplements the existing ‘Unfair Commercial Practices Directive’ (2005/29/EC) and the ‘Consumer Rights Directive’ (2011/83/EU). The title ‘Empowering consumers for the green transition’ is also abbreviated to ECGT or EmpCo. The directive entered into force on 26 March 2024 and has applied since 27 September 2026. Germany transposed the directive into German law in February 2026 through two legislative acts: Germany implemented Article 1 of the EU directive with the ‘Third Law Amending the Act Against Unfair Competition (UWG)’. Article 2 of the EU directive was implemented in the ‘Act Amending Consumer Contract and Insurance Contract Law and Amending Treatment Contract Law’.

 

With the EU directive ‘Empowering Consumers for the Green Transition’, EmpCo for short, the European Union aims to better protect consumers against misleading environmental claims. At the same time, companies that provide credible, transparent and verifiable information about environmental performance are to be supported.

This is an important development for the EU Ecolabel: as the official ecolabel of the European Union, it offers consumers reliable guidance and helps certified companies to credibly communicate environmental benefits.

EmpCo Directive to combat greenwashing

Why are new rules needed?

Many of a product’s environmental impacts are not immediately apparent at the time of purchase. Consumers are often unable to tell whether a product has been manufactured in a resource-efficient way, contains substances of concern, is durable, or is designed to be recyclable. This is precisely where trustworthy ecolabels come in: they make environmental performance visible and verifiable.

The new rules should above all prevent generic or unclear environmental claims from influencing purchase decisions without being adequately substantiated. The aim is to provide consumers with clear, understandable and accurate information – and to ensure that companies with recognised excellent environmental performance can compete on fairer terms. 

What is changing as a result of EmpCo?

EmpCo significantly tightens the requirements on advertising with environmental claims. Generic environmental claims such as “environmentally friendly”, “sustainable”, “ecological”, “green” or comparable claims will need to be substantiated and clear. Companies are not permitted to use such claims in a general manner if they cannot provide specific evidence of what the environmental benefit relates to.

In particular, misleading claims that refer to the product as a whole, even though they only relate to an individual attribute, are not permitted – for example, if a product is advertised as particularly environmentally friendly, although the claim only relates to the packaging. Claims about climate impact that only concern offsetting are also significantly restricted. 

In addition, sustainability labels must only be used in the future if they are based on a transparent certification scheme or have been established by public authorities. This applies, in particular, to self-developed labels that have not been independently verified or invented “green” labels. 

In Germany, the requirements have been implemented through amendments to the Act Against Unfair Competition. The new rules have applied since 27 September 2026.

What does that mean for consumers?

For consumers, EmpCo above all means greater clarity. Environmental advertising should become more transparent in the future. Anyone who buys a product should be better able to identify whether an environmental claim is actually substantiated and whether it relates to the product as a whole, to individual elements or to certain life-cycle phases.

The EU Ecolabel serves as a guide here. It is only awarded to products and services that fulfil defined environmental criteria. These criteria consider relevant environmental aspects across the product life cycle – depending on the product group, for example, raw materials, energy consumption, substances of concern, usability, longevity or disposal.

Where the EU Ecolabel is displayed, the environmental performance has been assessed against transparent criteria.

Which environmental claims can be used with the EU Ecolabel – and which are prohibited?

Since 27 September 2026, generic environmental claims are only permitted if recognised excellent environmental performance can be demonstrated. The EU Ecolabel, established under Regulation (EC) No 66/2010, qualifies as evidence of such performance. Generic environmental claims are therefore possible in principle for certified products and services. However, each claim must be supported by the criteria applicable to the relevant product group.

Generally possible – depending on the applicable criteria

Generic environmental claims that may be considered for products and services with EU Ecolabel certification include:

  • environmentally friendly
  • gentle on the environment
  • environmentally sound
  • environmentally compatible
  • green
  • ecological
  • nature-friendly
  • climate-friendly
  • carbon-friendly
  • energy-efficient
  • biodegradable
  • biobased

This list does not constitute blanket approval: each claim should be checked against the EU Ecolabel criteria for the relevant product group.

The EU Ecolabel can also support the use of product names with environmental references, such as “Green” or “Eco”. Specific claims about certified attributes, such as “low-emission product”, are also possible, provided that they are covered by the criteria for the relevant product group.

Practical guidance for companies

  • Link claims to the criteria: clearly explain the environmental benefit and relate it to the relevant product group or certified attributes.
  • Make packaging claims clear: distinguish whether a claim refers to the product as a whole, its packaging or an individual aspect. If only the packaging is made from recycled materials, this must be clearly stated.
  • Use product names with environmental references alongside the EU Ecolabel: companies are encouraged to display the EU Ecolabel whenever they communicate such names.

Claims and practices that are not permitted

  • Climate-related product claims based on carbon offsetting: claims that a product has a neutral, reduced or positive climate impact based on carbon offsetting are prohibited. Examples include claims such as “climate-neutral”, “CO₂-neutral”, “climate-positive”, “net zero” or “emission-free” when based on offsetting. The EU Ecolabel does not certify climate neutrality and cannot be used to substantiate such claims.
  • Generic environmental claims without appropriate evidence: generic environmental claims are not permitted if the underlying recognised excellent environmental performance cannot be demonstrated. The EU Ecolabel is one way of providing this evidence.
  • Sustainability labels without an appropriate basis: labels are not permitted if they are neither based on a certification scheme nor established by public authorities.
  • Misleading claims about the product as a whole: an environmental benefit that only relates to the packaging or an individual aspect must not be presented as a benefit of the entire product.

Please note: Additional sector-specific legislation, including the CLP Regulation for certain products, may impose further restrictions on environmental claims used on labels and packaging

What does this mean for certified companies?

EmpCo offers an opportunity for companies with EU Ecolabel certification. After all, certified products and services already have an independent basis for credible environmental communication.

In the future, the EU Ecolabel can serve as reliable evidence whenever environmental benefits are communicated – provided that the respective claim is covered by the criteria for the corresponding product group. Companies should thus ensure that their communication is closely aligned with the certified product attributes and the applicable EU Ecolabel criteria. 

This means: claims such as “more environmentally friendly”, “low in harmful substances” or “resource-efficient” cannot be used arbitrarily. They should always correspond to the specific requirements that the product fulfils as part of the EU Ecolabel certification.

In the individual product-specific EU Ecolabel criteria, the last criterion is always “Information appearing on the EU Ecolabel”. This was drawn up as part of the criteria development process and offers a particularly high level of assurance regarding the use of environmental claims.

Why the EU Ecolabel offers assurance

The EU Ecolabel is the official European Union voluntary label for environmental excellence. It stands for products and services that fulfil rigorous environmental requirements. Awarding takes place on the basis of transparent criteria and independent verification.

As a result, the EU Ecolabel is among the environmental labels that help companies to communicate credibly and offer consumers a reliable decision-making aid. The new EmpCo rules thus strengthen the importance of credible, independently verified ecolabels.

The EU Ecolabel is a strong tool for certified companies: it makes environmental performance visible, transparent and verifiable. Those who align their communication with the EU Ecolabel criteria can build trust and position themselves credibly in the market.

You can find more information here

Questions & Answers from the European Commission on EmpCo: 
https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_en?filename=faq-empowerting-consumers-gtd.pdf

German Environment Agency (2026): Stärkerer Schutz vor Greenwashing in deutsches Recht umgesetzt [Greater protection against greenwashing transposed into German law], online: 
https://www.umweltbundesamt.de/themen/staerkerer-schutz-vor-greenwashing-in-deutsches

Webinar “EU Ecolabel: How Companies Gain a Competitive Edge Through Credibility,” held on 11 June 2026 and hosted by the European Consumer Organisation (BEUC), the European Environmental Bureau (EEB) and Ecopreneur.eu:
https://www.youtube.com/watch?v=NPvtkxlCGzc 

Note: This article offers general guidance and does not replace legal advice. Companies should have their specific environmental communication reviewed on an individual basis.