The short answer
The Green Claims Directive is still a proposal with no application date. EmpCo, Directive (EU) 2024/825, is adopted law: Member States must transpose it by 27 March 2026 and apply it from 27 September 2026. If you are planning campaigns or packaging today, plan around EmpCo.
Most teams meet these two files in the wrong order. The Green Claims Directive got the headlines, so it is the name people search for, while the rules that actually bite first arrived quietly inside an amendment to existing consumer law.
Side-by-side comparison
| EmpCo (2024/825) | Green Claims Directive | |
|---|---|---|
| Legal status | Adopted and in force at EU level | Proposal, still under negotiation |
| Instrument | Directive (EU) 2024/825 | Proposed directive on green claims (COM/2023/166) |
| What it changes | Amends the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU) | Would create a separate substantiation and verification regime |
| Core mechanism | Prohibits listed practices, including generic claims, offsetting-based carbon neutrality and self-made labels | Would require evidence and third-party verification before an explicit claim is used |
| Labels | Bans sustainability labels not based on a certification scheme or set by public authorities | Would regulate new labelling schemes and their approval |
| Key dates | Transposition 27 March 2026, applies 27 September 2026 | No adoption or application date set |
| What to do | Comply now, working backwards from your longest artwork lead time | Monitor, and build substantiation files that would satisfy it |
For the full list of practices EmpCo prohibits, see banned claims.
What is the Green Claims Directive?
The Green Claims Directive is a proposed EU directive on the substantiation and communication of explicit environmental claims. It would require companies to prove and have independently verified any explicit environmental claim before using it, and it would set rules for environmental labelling schemes. It has not been adopted, so it is not law today.
In practice it is the evidence law. Where EmpCo names the claims you may not make, the Green Claims Directive would ask, before publication, what your claim is based on, how it was measured, whether the assessment covers the whole life cycle and who checked it.
Is the Green Claims Directive in force?
No. The Green Claims Directive is still a legislative proposal under negotiation between the European Parliament and the Council, and its final scope and timing are not settled. The rules that are already adopted and dated are in the Empowering Consumers for the Green Transition Directive, Directive (EU) 2024/825, known as EmpCo.
Because the text is not final, any agency deck or supplier questionnaire quoting exact Green Claims Directive obligations and dates is quoting a moving target. Treat it as a direction of travel, and treat EmpCo as the deadline.
Which one should you plan around now?
Plan around EmpCo. It is adopted, its dates are fixed, and national rules apply from 27 September 2026. Track the Green Claims Directive, but do not delay EmpCo work while waiting for it. Substantiation work done for EmpCo is also the groundwork for the Green Claims Directive if it is adopted.
- 1. Inventory every environmental claim you make, per market and per channel.
- 2. Triage each claim against the EmpCo prohibitions using the claim checker.
- 3. Build a substantiation file for every claim you keep. That file is what the Green Claims Directive would ask for.
- 4. Sequence rewrites by lead time against the EmpCo timeline.
Common questions
- What is the Green Claims Directive?
- The Green Claims Directive is a proposed EU directive on the substantiation and communication of explicit environmental claims. It would require companies to prove and have independently verified any explicit environmental claim before using it, and it would set rules for environmental labelling schemes. It has not been adopted, so it is not law today.
- Is the Green Claims Directive in force?
- No. The Green Claims Directive is still a legislative proposal under negotiation between the European Parliament and the Council, and its final scope and timing are not settled. The rules that are already adopted and dated are in the Empowering Consumers for the Green Transition Directive, Directive (EU) 2024/825, known as EmpCo.
- What is the difference between EmpCo and the Green Claims Directive?
- EmpCo bans specific misleading practices by amending existing EU consumer law, and applies from 27 September 2026. The Green Claims Directive would add an up-front duty to substantiate and independently verify explicit environmental claims before they are used. EmpCo tells you what you may not say. The Green Claims Directive would tell you what you must prove first.
- Which one should my marketing team plan around now?
- Plan around EmpCo. It is adopted, its dates are fixed, and national rules apply from 27 September 2026. Track the Green Claims Directive, but do not delay EmpCo work while waiting for it. Substantiation work done for EmpCo is also the groundwork for the Green Claims Directive if it is adopted.
- When will the Green Claims Directive apply?
- No application date exists yet, because the directive has not been adopted. Once an EU directive is adopted, Member States normally get a transposition period of roughly two years before national rules apply, so any obligations would land well after EmpCo.
- Does the Green Claims Directive replace EmpCo?
- No. The two are designed to work together. EmpCo edits the Unfair Commercial Practices Directive to prohibit named greenwashing practices, while the Green Claims Directive would sit alongside it as the evidence and verification regime for explicit environmental claims.
More answers on the FAQ page, and definitions in the glossary.