EmpCo Directive to combat greenwashing

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.

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.

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 are implemented by means of amendments to the Act Against Unfair Competition. As things stand at present, the new rules will apply from 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.

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.

What companies should pay attention to

Companies that advertise with the EU Ecolabel should review their environmental communication in good time. The following are particularly important:

• Formulate environmental claims precisely: Instead of generic advertising claims, companies should explain what the environmental benefit consists of – for example, by referring to the relevant product group or the certified characteristics.
• Compare claims with the criteria: Every environmental claim should be covered by the requirements of the EU Ecolabel for the specific product group.
• Do not use any generic climate pledges: Claims such as “climate neutral” or comparable formulations should be reviewed with particular care, especially if they are based on offsetting measures.
• Do not use any self-created sustainability labels without a sound basis: EmpCo strengthens labels that are based on independent, transparent certification schemes or established by public authorities.
• Make a clear distinction between the product, packaging and individual aspects: If an environmental benefit only relates to the packaging, an ingredient or a certain attribute, this must be clearly identifiable.

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

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