EmpCo Directive (EU) 2024/825 – the essentials for companies
What the EU directive on environmental claims means from September 2026
What is the Empowering Consumers Directive (EmpCo, EU Directive 2024/825)?
The Empowering Consumers Directive (EmpCo, EU Directive 2024/825) strengthens consumer protection against misleading environmental advertising. Adopted in March 2024, its provisions apply from 27 September 2026. It is distinct from the separate Green Claims Directive proposal.
Goal: enable consumers to make informed purchasing decisions based on truthful environmental information.
Timeline & deadlines
März 2024
Adoption by the European Parliament
March 27, 2026
Deadline for transposition into national law
September 27, 2026
Start of application of the regulations
Enforcement & consequences
Competitors & associations
Cease-and-desist letters from competitors or organisations such as the German Environmental Aid (civil law – the main route)
Market surveillance authorities
National authorities can impose fines and stop product sales
Civil courts
Coercive penalties for violations of cease-and-desist declarations – up to €250,000 per violation
Up to 10% of annual turnover
Maximum fine for serious violations under EmpCo
Key requirements of the directive
Evidence obligation
Specific environmental claims need a clear scope and appropriate, verifiable evidence.
Ban on vague statements
Under EmpCo, generic environmental claims without recognised excellent environmental performance are prohibited from 27 September 2026.
Sustainability labels
EmpCo does not require every environmental claim to undergo independent pre-approval. Sustainability labels must be based on a certification scheme or established by public authorities.
Comparability
Comparative claims must relate to the same product categories and be scientifically substantiated
Carbon neutrality
EmpCo prohibits claims that a product has a neutral, reduced or positive environmental impact based on greenhouse-gas offsetting.
Transparenz
Consumers must be given easy access to all evidence and calculation methods
Do's & don'ts – EmpCo at a glance
The most important rules for your sustainability communication under the Empowering Consumers Directive (EU 2024/825).
Don'ts – Avoid
- ✗ «Our product is climate neutral through offsetting» – product neutrality claims based on greenhouse-gas offsetting are prohibited.
- ✗ "Environmentally friendly product" – vague overall statement without a concrete reference
- ✗ "100% sustainable" – absolute statement without scientific basis
- ✗ "Greener than the competition" – inadmissible comparison without standardised methodology
- ✗ Using your own environmental labels without independent verification
- ✗ Equating offsetting with avoidance – presenting offset projects as equivalent to actual emission reductions
Do's – How to get it right
- ✓ "CO₂ emissions reduced by 30% (Scope 1+2, base year 2020, per the GHG Protocol)"
- ✓ "Packaging made from 65% recycled PET (TÜV-tested)"
- ✓ «Cradle-to-Cradle Gold» – recognised third-party certification
- ✓ «We invest in reforestation projects (Gold Standard)» – clearly communicated as an investment, not as neutrality
- ✓ Link evidence and calculations publicly
- ✓ Regular pre-publication review of all new claims
Compensation & environmental investments
Under the EmpCo, compensation measures (e.g. CO₂ offsetting) are not to be considered equivalent to actual emission avoidance. Claims such as «climate-neutral through offsetting» will no longer be permitted going forward.
Businesses can describe specific environmental investments without claiming that a product is climate neutral. Assess the wording and evidence in each case:
Not permitted
«Our product is climate-neutral» (through offsetting)
Specific information
«We invest €50,000 annually in Gold Standard climate protection projects»
How to prepare
Inventory
Inventory all current green claims on your website, packaging, social media and advertising materials
Evidence check
Check for each claim whether sufficient scientific evidence, certificates or LCAs are available
Eliminate risky claims
Remove or refine vague statements such as "sustainable" without concrete evidence
Establish processes
Implement approval workflows so new claims are reviewed before publication
Set up monitoring
Continuously monitor all communication channels for new or outdated claims
EmpCo and environmental advertising: what changes
EmpCo amends EU consumer protection rules and applies through each Member State’s national law. Germany’s UWG is one national implementation.
Generic environmental claims
Generic environmental claims require recognised excellent environmental performance relevant to the claim.
Neutrality claims
Statements that a product is climate neutral, or has a neutral climate impact, through offsetting are not allowed.
Comparative claims
“More eco-friendly than …” or “better for the climate” requires robust, verifiable and comparable data.
National law in the relevant Member State determines the details. This page offers guidance, not legal advice.
Frequently asked questions on the EmpCo Directive
When does the EmpCo Directive apply?
Member States were required to transpose the directive by 27 March 2026; its provisions apply from 27 September 2026.
Which generic environmental claims are banned?
Generic environmental claims require recognised excellent environmental performance relevant to the claim. Specific claims need a clear scope and suitable evidence.
Is “climate neutral” still allowed?
EmpCo prohibits claims that a product has a neutral, reduced or positive environmental impact based on greenhouse-gas offsetting.
Does the Directive apply to companies outside the EU?
Yes, if you trade in the EU. What matters is the market on which the advertising appears.
Which evidence do we need?
Substantiate every claim with a source: certificate, measured value, contract or report. Document validity and responsibility.
Align with EU 2024/825 with VERDAI
Automatic classification, evidence management and continuous monitoring for all your green claims – as an independent orientation aid
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