What does EmpCo actually do?
EmpCo amends two existing EU laws – the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU) – to outlaw specific greenwashing practices and to force clearer information about durability and repairability.
That structure matters. EmpCo is not a new standalone rulebook you can put in a separate folder. It edits the law that already governs every ad you run, which means the enforcement machinery, the national regulators and the penalties are already in place and simply gain new grounds to act on.
Who does it apply to?
Any trader making commercial communications to consumers in the EU, regardless of where the company is headquartered or how large it is.
There is no reporting threshold like CSRD has. A small brand selling one product into one EU market is covered in exactly the same way as a multinational. And the scope is commercial communication in the broad sense: packaging, point of sale, TV, retail media, influencer content, product pages, sales decks shown to consumers.
Why was it introduced?
Because the EU found the market flooded with environmental claims that consumers could not check, which made honest sustainability work impossible to reward.
The logic behind the directive is competitive, not punitive: if unverifiable claims are free, they crowd out substantiated ones. Removing them is meant to restore the price of a credible claim – which is good news for brands that have done the work.
When does it take effect?
Member States must transpose EmpCo into national law by 27 March 2026 and apply those rules from 27 September 2026.
Because it is a directive rather than a regulation, the detail – especially penalties and enforcement practice – is set nationally. Expect variation between markets and check each one you sell in. See the timeline.
How is EmpCo different from the Green Claims Directive?
EmpCo is adopted law that bans specific practices. The Green Claims Directive is a separate, later proposal that would add up-front substantiation and verification requirements for explicit environmental claims.
| EmpCo (2024/825) | Green Claims Directive | |
|---|---|---|
| Status | Adopted, in force | Proposal, still under negotiation |
| Approach | Bans listed practices | Requires proof before you claim |
| Plan around it | Yes, now | Watch, don't wait for it |
What should a marketing team do first?
Inventory every environmental claim you currently make, then classify each one against the banned practices and fix or retire the failures.
- 1. Pull every claim from packaging, site, ads, retail media and sales material into one list.
- 2. Mark the owner and the evidence for each claim. No evidence, no claim.
- 3. Run each one through the claim checker to triage.
- 4. Sequence fixes by lead time – artwork first, digital last.