EmpCo — Empowering Consumers Directive
Anti-greenwashing rules from September 2026. Generic green claims, offset-based neutrality claims, and unverified sustainability labels are prohibited.
Overview
The Empowering Consumers for the Green Transition Directive (EmpCo) — Directive (EU) 2024/825 — is the EU's anti-greenwashing framework. From September 2026, it prohibits generic environmental claims, offset-based neutrality claims, and unverified sustainability labels.
Legal basis
- Proposed: 22 March 2022
- Adopted: 28 February 2024
- Member state transposition: 27 March 2026
- Application date: 27 September 2026
Key prohibitions (from September 2026)
- Generic green claims prohibited — "eco-friendly," "green," "carbon-friendly," "nature positive" banned without proven excellent environmental performance
- Offset-based neutrality claims prohibited — "carbon neutral" claims based on carbon offsets are banned
- Unverified sustainability labels — only public authority or third-party certified labels permitted; no self-created labels
- Future commitments without detailed, verified implementation plans prohibited
- Durability claims must be substantiated with test results
Positive obligations
Companies making sustainability claims must:
- Provide substantiation before making the claim
- Use verifiable, reliable methodology
- Be prepared to demonstrate compliance to authorities
Relationship to DPP
DPP data can substantiate EmpCo-compliant claims:
- Carbon footprint data in DPP supports specific environmental claims
- Recycled content data supports recycled material claims
- Repairability scores support durability claims
- Recyclability data supports end-of-life claims
Companies should align marketing with DPP data fields to ensure claims are substantiated.
Who is affected
- All traders making environmental or sustainability claims about products or services to EU consumers, regardless of company size
- Applies to: manufacturers, brand owners, importers, retailers, and service providers
- Covers B2C commercial communications — labelling, advertising, packaging text, websites, social media, and catalogues
- Non-EU companies whose products are sold or marketed in the EU are equally in scope
Penalties and enforcement
Member States must establish effective, proportionate, and dissuasive penalties applicable from 27 September 2026. The directive sets a minimum penalty floor:
- At least 4% of annual turnover in the affected member state(s) where the infringement occurred
- Where turnover data is unavailable: a maximum fine of at least €2 million
- Additional consequences include: injunctions requiring immediate withdrawal of the misleading claim, mandatory corrective statements, and temporary prohibition from making environmental claims
Relationship to UCPD
EmpCo amends the Unfair Commercial Practices Directive (UCPD — Directive 2005/29/EC) by inserting specific prohibitions for environmental and sustainability claims into the UCPD's black list and grey list of unfair practices. This means EmpCo violations are enforceable under existing UCPD national enforcement structures from 27 September 2026.
Note: Green Claims Directive withdrawn
The separate Green Claims Directive (requiring pre-market verification) was withdrawn in June 2025 due to SME burden concerns. EmpCo remains the primary anti-greenwashing framework. A replacement may be proposed under the new Commission mandate.
Key dates
| Date | Milestone | |------|-----------| | 6 March 2024 | Published in OJ | | 27 March 2026 | Member state transposition deadline | | 27 September 2026 | Anti-greenwashing rules apply |