EmpCo 2026: Which Environmental Claims Are Now Risky in the EU?

A practical guide to carbon-neutral claims, green labels, future targets and the evidence brands should retain

Last reviewed: 29 September 2026

The short answer

From 27 September 2026, new EU rules implementing the Empowering Consumers for the Green Transition Directive, commonly called EmpCo, apply to environmental claims made to consumers.

The rules do not prohibit companies from communicating environmental performance. They make certain practices automatically unfair and strengthen the evidence required for other claims.

Among the most important changes:

• unsupported generic claims such as “green” and “eco-friendly” are prohibited;
• offset-based claims that a product is carbon neutral, climate neutral or has a reduced climate impact are prohibited;
• private sustainability labels require an acceptable certification scheme;
• a claim about an entire product cannot be based only on one component;
• future claims such as “net zero by 2030” require a credible implementation plan and independent monitoring.

For brands, the practical question is no longer simply:

“Do we have some evidence for this claim?”

It is:

“Is this type of claim permitted, is its wording no broader than the evidence, and could a consumer understand exactly what was measured?”

What is EmpCo?

EmpCo is Directive (EU) 2024/825. It amends the EU Unfair Commercial Practices Directive and Consumer Rights Directive to address misleading environmental and social claims and improve information about durability and repairability.

EU Member States were required to transpose the directive by 27 March 2026 and apply their implementing measures from 27 September 2026.

Because it is a directive, enforcement takes place through the national laws of individual Member States. Companies should therefore review both the EU requirements and the implementing law of each relevant market.

EmpCo principally concerns business-to-consumer commercial practices. However, manufacturers supplying retailers and consumer brands may still receive more detailed carbon and environmental-data requests because their customers need evidence for downstream claims.

The claims most affected by EmpCo

1. Generic environmental claims

A generic environmental claim may be prohibited where the company cannot demonstrate recognised excellent environmental performance relevant to the claim.

Examples include:

• green;
• eco-friendly;
• environmentally friendly;
• climate friendly;
• carbon friendly;
• ecological;
• kind to the environment;
• biodegradable;
• energy efficient.

Adding one of these expressions to packaging does not become acceptable simply because the company has completed a carbon footprint or improved one environmental indicator.

The claim may imply performance across several environmental impacts, while the evidence may cover only carbon emissions, packaging or energy consumption.

Risky claim

An eco-friendly product.

More specific alternative

The bottle contains 50% post-consumer recycled plastic by weight.

The narrower statement still requires evidence, but it tells consumers what has actually changed.

2. Claims about the whole product based on one feature

A company cannot present an environmental benefit as applying to the entire product or business when it concerns only one aspect.

Risky claim

Our sustainable shampoo.

Evidence: the bottle contains recycled plastic.

More specific alternative

The bottle, excluding the cap and label, contains 50% post-consumer recycled plastic by weight.

The formula, manufacturing, packaging and distribution may have different environmental impacts. An improvement to the bottle does not automatically make the entire shampoo “sustainable.”

The same principle applies to carbon claims.

Risky claim

This is a low-carbon product.

Evidence: the factory purchased renewable electricity.

That evidence may not cover materials, processing, packaging or other emissions within the intended product boundary.

3. Carbon-neutral claims based on offsetting

EmpCo adds to the list of commercial practices considered unfair in all circumstances:

Claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.

This affects expressions including:

• carbon neutral;
• climate neutral;
• CO2 neutral;
• climate positive;
• carbon compensated;
• net-zero product;
• reduced climate impact, where the claimed reduction results from offsetting.

Purchasing carbon credits does not reduce the emissions physically embedded in the product. Under EmpCo, those credits cannot be used as the basis for telling consumers that the product itself is carbon neutral or has a reduced climate impact.

Companies may still communicate factual information about financing environmental or climate projects, provided that the communication does not claim that offsetting changed the product’s own environmental impact.

Risky claim

Carbon-neutral T-shirt.

Evidence: calculated emissions were offset through carbon credits.

Potentially clearer disclosure

We calculated the product’s cradle-to-gate carbon footprint as X kg CO2e. Separately, the company financed a third-party climate project. That financing does not reduce the reported product footprint.

The project and the product footprint should remain clearly separated.

4. Future environmental targets

Claims about future performance are not automatically prohibited, but EmpCo substantially raises the expected standard.

Statements such as:

• net zero by 2030;
• carbon free by 2040;
• all products will be sustainable by 2028;
• we will halve our environmental impact;

may be misleading unless they are supported by:

• clear, objective and publicly available commitments;
• a detailed and realistic implementation plan;
• measurable, time-bound targets;
• allocation of appropriate resources;
• regular verification by an independent third-party expert;
• findings made available to consumers.

Weak claim

We will become net zero by 2030.

Better-supported communication

We aim to reduce Scope 1 and Scope 2 emissions by 50% from a 2024 baseline by 2030. Our implementation plan, progress data, methodology and independent review are available here.

Changing “will” to “aim to” does not solve an evidence problem by itself. The scope, baseline, actions and progress still need to be credible.

5. Sustainability labels

Displaying a sustainability label is prohibited if the label is not based on an acceptable certification scheme or established by a public authority.

This creates risk for:

• self-created green leaves;
• internal “planet approved” badges;
• supplier-awarded environmental seals;
• logos that look like certification marks but have no independent scheme;
• pay-to-use badges without adequate third-party verification.

A certification scheme must meet the directive’s requirements, including transparent criteria and independent verification. A logo is not made compliant merely by calling it a “standard.”

Brands should create a register showing:

• every label in use;
• the scheme owner;
• applicable criteria;
• verification body;
• certificate number;
• product scope;
• validity period;
• renewal status.

6. Legal requirements presented as special benefits

A company cannot present compliance with a legal requirement applying to all products in the category as a distinctive product advantage.

Risky claim

Better for the planet because it complies with the EU’s mandatory substance restriction.

If every competing product legally sold in that market must meet the same requirement, presenting compliance as a unique environmental feature may mislead consumers.

Does EmpCo prohibit quantified carbon-footprint claims?

Not automatically.

A claim such as:

Product carbon footprint: 8.4 kg CO2e per unit

is different from saying that the product is “green” or “carbon neutral.” However, the number must still be accurate, relevant and presented without misleading omissions.

A useful evidence file should explain:

• the product and version assessed;
• declared or functional unit;
• system boundary;
• reporting and production periods;
• methodology and standards applied;
• primary and secondary data used;
• emission-factor sources and versions;
• treatment of missing supplier data;
• allocation and recycling assumptions;
• exclusions and limitations;
• calculation review or verification status.

The claim should also identify the boundary in language consumers can understand. For example, a cradle-to-gate result should not be presented in a way that implies it covers customer use and end-of-life.

What about “30% lower carbon footprint”?

Comparative claims require more than two numbers.

Before publishing the statement, determine:

1. Lower than what?

The previous product version, another company’s product or a market average?

1. Are the products comparable?

They should perform an equivalent function and use consistent units.

1. Were the same boundaries used?

A cradle-to-gate result cannot be fairly compared with a cradle-to-grave result.

1. Were the same methodologies and emissions factors used?

Methodological changes can create an apparent reduction without a real production improvement.

1. Is the baseline still representative?

An old or exceptional baseline can exaggerate progress.

1. What caused the reduction?

Material changes, energy changes, supplier changes or only a revised calculation?

A clearer claim would be:

The cradle-to-gate carbon footprint of the 2026 model is 30% lower than the 2024 model, calculated per product using the same system boundary and methodology. The main reductions came from recycled aluminium and lower manufacturing-energy consumption.

This is still not automatically compliant, but it is more transparent and testable than “30% greener.”

A practical EmpCo claims review

Review every consumer-facing environmental statement across:

• product packaging;
• labels and hangtags;
• product pages;
• advertising;
• social media;
• catalogues;
• point-of-sale displays;
• QR-code content;
• retailer-provided product descriptions.

For each claim, record:

Classify each claim as:

• remove: the practice is prohibited or cannot be supported;
• rewrite: evidence exists, but the wording is too broad;
• retain with evidence: the claim is specific and adequately substantiated;
• escalate: legal, technical or certification review is required.

Evidence first, wording second

A product carbon footprint does not give a company permission to use any environmental wording it chooses.

It can, however, support specific statements when the calculation is:

• based on an appropriate methodology;
• traceable to product and supplier data;
• version-controlled;
• transparent about boundaries and assumptions;
• reviewed at the level appropriate to the claim.

The safest process is to connect every published claim to a controlled evidence record. When a product, supplier, emissions factor or calculation changes, the company should be able to identify which claims require review.

Preparing carbon evidence for product claims? ClimateSeal can help organise product, supplier and emissions data into a traceable PCF record. Legal approval of consumer-facing wording should remain part of the company’s claims-review process.

This article provides general information and is not legal advice. EmpCo is implemented and enforced through national law. Companies should confirm requirements and penalties in each EU market where their claims are used.

Official reference

Directive (EU) 2024/825 on empowering consumers for the green transition