The quick answers
EmpCo Directive FAQ
The questions marketing, brand and comms teams ask most about Directive (EU) 2024/825.
What is the EmpCo Directive?
- EmpCo is the common name for Directive (EU) 2024/825 on empowering consumers for the green transition. It amends the Unfair Commercial Practices Directive and the Consumer Rights Directive to ban greenwashing, unreliable sustainability labels and misleading durability information across the EU.
When does the EmpCo Directive apply?
- EU countries must transpose it into national law by 27 March 2026 and apply those rules from 27 September 2026. Marketing that is live on that date must already comply.
Who does the EmpCo Directive apply to?
- Any trader making commercial communications to consumers in the EU, regardless of where the company is based. It covers packaging, advertising, websites, social content, retail media and sales conversations – not only formal sustainability reporting.
Can I still say my product is climate neutral?
- Not if the claim rests on carbon offsetting. EmpCo bans claiming a neutral, reduced or positive environmental impact on emissions on the basis of offsetting. You can still report verified reductions in your own footprint, and describe climate contributions separately.
Are words like eco-friendly and green banned?
- Generic environmental claims are banned unless you can demonstrate recognised excellent environmental performance relevant to the claim, for example an EU Ecolabel. In practice, most brands should replace generic adjectives with specific, evidenced attributes.
Can we keep our own sustainability logo?
- Only if it is based on a certification scheme with published criteria, independent third-party verification and monitoring, or was established by a public authority. Self-created badges are banned.
How is EmpCo different from the Green Claims Directive?
- EmpCo is adopted law that bans specific practices. The Green Claims Directive is a separate proposal that would add ex-ante substantiation and verification requirements for explicit environmental claims. EmpCo is what you must plan for now.
What are the penalties for breaching EmpCo?
- Penalties are set nationally, under the Unfair Commercial Practices Directive framework. For widespread cross-border infringements that framework allows fines of at least 4% of annual turnover in the Member States concerned. Check the national implementation in each market.
Where do we start?
- Inventory every environmental claim you currently make, classify each against the banned practices, and fix or retire the ones that fail. Start with packaging artwork, because print lead times are the longest constraint before September 2026.