The EU’s Empowering Consumers for the Green Transition Directive (EmpCo) introduces stricter rules on how companies communicate environmental performance to consumers. It amends the Unfair Commercial Practices Directive (UCPD) to address misleading environmental claims and improve transparency.
At its core, EmpCo tightens the requirements for environmental communication: claims must be clear, specific and substantiated, and in many cases, supported by independent verification.
For companies operating in, or selling into, EU member states, this directly affects how products are marketed across packaging, digital channels and retail environments.
Key dates:
- In 2024 – Directive was approved and published in EU law
- By 27 March 2026 – Member states must implement into national law
- By 27 September 2026 – Rules become applicable and enforceable
While enforcement begins in 2026, the operational implications start earlier. Updating claims, validating supporting data, and aligning internal processes across portfolios takes time, particularly for companies with complex product ranges.
Who does it impact?
EmpCo applies to B2C commercial practices in the EU.
It’s relevant for any company that:
- Sells products or services in the EU
- Makes environmental claims about products or services
- Uses sustainability labels, badges or external-facing frameworks
- Communicates environmental targets linked to products or performance
This includes both manufacturers and retailers. Responsibility extends across the full chain of commercial communication, from product packaging to on-shelf labeling to online product pages.
What does this mean for my business?
As these requirements come into effect, EmpCo may change how environmental sustainability claims are developed, reviewed, approved and communicated to consumers.
In practice, this means:
- Product-level performance becomes more important
Claims need to reflect actual product characteristics rather than general brand positioning. - Internal governance needs to strengthen
Marketing, sustainability, legal and product teams must align around a shared evidence base and review process. - Existing claims will need to be reassessed
Some claims may need to be refined, reframed or removed depending on the strength of supporting evidence.
- Consistency across markets becomes more complex
Claims used in the EU must meet stricter requirements, even if messaging differs in other markets.
EmpCo will have differentiated but significant impacts across sectors, particularly for industries with high exposure to consumer-facing claims.
This sector is expected to be among the most impacted due to its reliance on marketing-driven sustainability positioning (e.g. “natural”, “clean beauty”, “eco-friendly”). EmpCo will require a shift away from broad, perception-based claims toward specific, evidence-based product statements. Common practices such as ingredient-led claims (“free from”, “non-toxic”) or self-declared labels will face increased scrutiny, while carbon neutrality claims based on offsetting will no longer be permitted. As a result, brands will need to revisit product naming, packaging design, and storytelling, and invest in robust substantiation (e.g. lifecycle data, third-party certifications).
Environmental claims are widely used across food and beverage products, particularly around sourcing, emissions and production practices. Under EmpCo, these claims will need to be more precise and tied to verified product-level data, reducing reliance on broad, unsubstantiated statements. Areas such as “sustainably sourced” ingredients, carbon-related claims and production methods will come under greater scrutiny, especially where evidence is inconsistent or aggregated at company level. On-pack labels and certification schemes may also face closer examination where criteria are unclear or not independently validated. This will require stronger alignment between sourcing, product formulation and claims, as well as improved data visibility across complex agricultural value chains.
The Fashion and Sporting Goods sector, as a client-facing industry, has recently been under the spotlight for instances of misleading communication, and a few players have already received fines from local consumer protection authorities related to Green Claims. The sector is already highly sensitive to the reputational and compliance risks arising from the use of vague claims, such as “eco,” “conscious,” and “green,” and references to alleged circularity. A key concern for the sector is the scalability of sustainability claims, which may refer to a portion of the materials used, pilot collections, as well as end-of-life recyclability claims contradicted by the use of mixed fibers, and therefore impossible to recycle. The European PEFCR framework for apparel and footwear, approved by the European Commission in 2025, has defined harmonized rules for measuring environmental impact throughout the product’s entire life cycle, combating greenwashing and ensuring objective comparisons. Policy, at different geographies, addresses both greenwashing and greenhushing in the sector.
While more regulated in terms of product claims, pharma will still be impacted through corporate and product-related environmental communication, particularly for OTC products and consumer health brands. Claims related to packaging (e.g. recyclability), manufacturing footprint, or environmental targets (e.g. net zero commitments) will need to meet stricter substantiation and transparency requirements. In addition, companies will need to ensure that global sustainability messaging is adapted to EU-specific rules, creating complexity for multinational portfolios. EmpCo may also increase scrutiny on how environmental performance is communicated without overstating benefits in a highly regulated context.
Across these sectors, the directive accelerates a broader shift from marketing-led sustainability narratives to evidence-based communication frameworks, with implications for R&D, regulatory, and brand functions globally.
Where to assess your exposure to EmpCo
EmpCo introduces specific requirements that determine how environmental claims, labels and targets can be used in the market.
1. Environmental claims
All voluntary environmental claims must be:
- Clear, specific and not misleading
- Transparent about what aspect of the product or life cycle stage they refer to
- Substantiated with credible evidence (e.g., life cycle assessment or other environmental impact assessment)
Generic claims, such as “eco-friendly” or “green,” are not permitted unless they can be backed by recognized, high-level environmental performance and clearly explained.
Examples of impacted claims:
- “Lower carbon footprint”
- “Improved environmental performance”
- “Sustainable packaging”
2. Sustainability labels and badges
Labels are only allowed if they are:
- Established by a public authority, or
- Based on a certification scheme with independent third-party verification, transparent criteria, and open access
Examples:
- On-pack carbon labels with associated icons
- Internal programs or “green” product badges
Self-created labels that are not independently verified or based on recognized certification schemes are not permitted.
Environmental targets
Claims about future environmental performance must be supported by:
- A clear implementation plan
- Measurable and time-bound targets
- Publicly available information
- Regular monitoring and verification of progress
Examples:
- Net zero commitments
- Product-related emissions reduction targets
- Packaging commitments (e.g., recyclability targets)
Public environmental targets must be supported by documented delivery plans, not just stated ambition.
Penalties and risk of non-compliance
EmpCo will be enforced at the EU member state level, with penalties determined nationally:
In France, EmpCo will be enforced primarily under the Consumer Code by the DGCCRF, building on existing sanctions for misleading commercial practices. Companies may face administrative fines of up to €300,000 for legal entities (and €1.5 million in case of repeat offences), which can be increased to up to 10% of average annual turnover depending on the benefit derived from the infringement. EmpCo will reinforce an already strict regulatory framework (e.g. AGEC, Climate & Resilience laws) by introducing more stringent, harmonized EU rules on environmental claims. The transposition is expected to expand the list of automatically misleading practices, making enforcement by authorities more systematic and increasing legal risk for non-compliant companies.
In Germany, violations can lead to significant costs and consequences. For companies with an annual turnover of more than €1.25 million, fines of up to 4% of annual turnover may be imposed. In addition, competitors, the Centre for Protection against Unfair Competition (Wettbewerbszentrale), qualified consumer organizations, and civil courts can take action. More insights in our German article.
In Italy, the directive has been transposed into national law and is enforced by the competition authority (AGCM), which can impose fines of up to €10 million or 4% of annual turnover for misleading sustainability claims. For further insight into the Italian context and EMPCO’s national transposition, read our Italian article.
Non-compliance can result in:
- Financial penalties
- Removal or modification of claims and products
- Increased legal scrutiny and reputational exposure
More fundamentally, the directive reduces the margin for interpretation. Claims that are unclear, generic or insufficiently supported are more likely to be challenged.
Start preparing today
For many organizations, this is not about starting from scratch. It’s about taking a clear view of what is already in place, and where it may not meet the level of scrutiny required.
Focus your efforts where they matter most:
- Review current claims, labels and targets
Identify where claims are broad, unclear or unsupported - Assess substantiation
Ensure claims are backed by credible, documented evidence and consistent methodologies - Prioritize high-risk areas
Focus on product categories, claims or markets with the greatest exposure - Strengthen internal governance
Align sustainability, legal, marketing and product teams around clear validation processes
Quantis teams are prepared to support organizations in reviewing environmental claims, strengthening substantiation, and aligning labeling and targets with EmpCo requirements.
This content does not constitute legal advice. Quantis supports organizations in understanding and preparing for the implications of EmpCo.
We look forward to supporting your next steps on EmpCo.
