On 27 September 2026 the European EmpCo Directive enters into force, introducing new rules for green product claims. What does EmpCo mean in practice for your packaging, website, advertising and social media? And what are the risks of non-compliance? We explain it in this article.
The EmpCo Directive (Empowering Consumers for the Green Transition) prohibits a range of practices that are still commonplace in sustainability communications to consumers. The scope is broad: from packaging text and television advertising to website content, social media, and even brand names that refer to sustainability.
The key prohibitions:
Generic environmental claims without substantiation. Terms such as “eco”, “green”, “sustainable”, “climate-friendly” or “biodegradable” are no longer permitted unless they are supported, within the same communication, by a recognised label (such as the EU Ecolabel) or a recognised standard (such as ISO 14024). Implicit claims conveyed through colours, images or logos that suggest sustainability are also covered.
In-house labels without independent certification. A self-declared “green seal” without external verification is no longer permitted.
Climate-neutral claims based on offsetting. Claims such as “climate neutral”, “certified CO₂ neutral”, or “positive carbon balance” are prohibited where they are based on CO₂ offsetting outside the company’s own value chain.
Forward-looking claims without a plan, targets and verification. “By 2030 we will be climate neutral” is not permitted unless there is a realistic implementation plan with measurable targets, allocated resources and a credible timeline – verified by an independent party.
Irrelevant benefits. Claims referring to features that the product has by definition are prohibited – for example, “gluten-free” on mineral water, or “plastic-free” on paper.
Misleading social claims. Claims about working conditions, human rights or fair pay in the supply chain are subject to the same rules: specific, substantiated and verifiable.
Legal and financial. Infringements can be penalised with fines of up to 4% of annual turnover or a minimum of €80,000 – whichever is higher. Authorities may also require the withdrawal of advertising or removal of products from the market.
Supply chain risks. Major retailers and procurement teams will increasingly scrutinise their suppliers’ compliance. Businesses without proper documentation risk delays in product launches or losing access to certain sales channels.
Reputation and greenhushing. The opposite of greenwashing is an equally real risk: greenhushing. Businesses that stop communicating about their sustainability efforts altogether, out of fear of making mistakes, suffer reputational damage and miss the opportunity to tell a distinctive story. The solution is to communicate correctly and with substantiation.
Operational costs. Starting late costs more: reprinting packaging, redesigning labels, conducting LCAs, training marketing and legal teams. Starting early is cheaper than making last-minute adjustments.
Pantarein has developed a Green Claims Framework with five criteria for assessing whether a claim is in line with EmpCo:
1. Accurate – is the claim factually correct?
2. Specific – which product, which aspect, which scope does it refer to precisely?
3. Quantifiable – are there specific figures or measurable reference points?
4. Complete – are scope, boundaries and limitations transparent?
5. Verifiable and transparent – is external evidence available and accessible?
Communicating effectively about sustainability performance goes beyond compliance. Pantarein therefore also examines whether claims are material – do they address something that is genuinely impactful for this product? – and whether they are credible and consistent – does the claim fit the broader brand narrative?
Well-formulated claims therefore not only protect you legally. They also build trust with customers, retailers and investors – and that matters just as much.
To help businesses audit and improve their communications ahead of the September deadline, we launched the Greenwashing Scan, a structured five-step process.
Step 1 – Risk profile and relevance of claims
We map out all the claims your business makes and in what context: packaging, website, advertising, social media, brochures. We assess these against your business's material sustainability topics and decide together which areas are most urgent.
Step 2 – Substantive review
Each claim is assessed against the prohibited practices in the EmpCo Directive and against our own Green Claims Framework. This includes implicit claims conveyed through colours, images or logos that suggest sustainability.
Step 3 – Substantiation and credibility check
Is the claim factually correct? Are the data traceable at product level? But also: does the claim fit the broader brand narrative? A claim that is factually correct but raises credibility concerns is also a risk.
Step 4 – Revision and reformulation
We reformulate problematic claims in a way that is accurate, specific and compliant, without losing their impact. Good sustainability communication does not have to be dry or defensive.
Step 5 – Documentation
We ensure that the substantiation for each claim is documented and accessible. This is a requirement under the new legislation; at the same time it lays the groundwork for credible long-term communication.
September 2026 is not far away. Businesses that need to review and update all their communications – packaging, website, campaigns – will need that time. Particularly because the directive does not provide a transition period for products already on the market.
Want to know where your business stands before September? Discover the Pantarein Greenwashing Scan and book a no-obligation consultation with one of our experts via mail@pantarein.be.
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