EmpCo deadline approaching: what should you tackle first?

From 27 September 2026, your B2C communications must comply with the EmpCo Directive. Vague claims about the sustainability characteristics of products will no longer be permitted. What should you focus on in the coming weeks, and what can wait until afterwards?

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August 13, 2026

by

Katelijne Norga

Jonas Kiesekoms

Greenwashing

Under EmpCo, you may no longer make any sustainability claim that you cannot substantiate. Three types of claim are no longer permitted:

generic claims such as “green” or “environmentally friendly” without substantiation;
carbon-neutral claims that rely on offsetting emissions;
forward-looking claims – such as “climate neutral by 2035” – without a verifiable plan.

Claims that are factual, specific and verifiable are still permitted, provided they are supported by a methodologically sound life cycle assessment (LCA). Our earlier articles explain in more detail what is changing under EmpCo and how to substantiate a claim correctly.

Is there still enough time to get all of this in place? This article helps you assess what has to be in order before the deadline, what to set in motion now, and how to handle your claims in the meantime.

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Existing versus new claims

Not every company is in the same position, and not every claim involves the same amount of work. For each claim, however, the key question is the same: will you still be using it on 27 September? That determines whether you need to act today or can schedule a longer-term project.

In practice, that leaves two categories:

Claims you already use today and want to continue using after 27 September. These must be in order by that date. If they are generic or implicit claims without substantiation, you will need to remove them, reword them or withdraw them temporarily, without new measurements. If the data are already available and only the wording falls short, rewording is enough. If the substantiation is missing, you will need a LCA. As this will not be complete by 27 September, you should drop the claim or use it again only once the LCA is available.
Claims you intend to use only later – for example, a new claim for which the LCA is already under way. The substantiation process may run beyond the 27 September deadline; you use the claim once the LCA has been completed. What matters most here is setting the time-consuming work in motion now.

Worth bearing in mind: the directive makes no provision for a transition period for products already on the market. Packaging and campaign materials in circulation on 27 September fall into the first category – even if they were printed or launched months earlier. Belgium does allow a six-month grace period, so that products manufactured before 27 September do not have to be destroyed.

The category a claim falls into determines whether you take short-term action now or start a longer-term project.

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What to tackle in the coming weeks

Not every claim requires an LCA. A realistic, phased approach looks roughly like this:

In the short term (days to a few weeks)

Subject your existing claims to a risk scan: which terms, images or logos suggest sustainability without being backed by a recognised label or standard?
Draw up an inventory of the media on which your claims appear: packaging and labels, website and webshop, brochures and catalogues, and so on. The same claim often appears in several places, each with different lead times for making changes.
Withdraw or amend clearly problematic claims – generic terms without substantiation, or claims about properties that are inherent to the material (such as “recyclable” on a glass bottle).
Brief your marketing and legal teams on what is no longer permitted, so that no new risky claims are added while you review the existing ones.

In the medium term (up to the deadline)

Reword claims on the basis of data you already hold. Not every claim requires new measurement – often the underlying data do exist, but your communications still lack the necessary specificity, scope or basis for comparison.
Put your documentation in order for claims that are substantively correct but whose substantiation is not yet traceable or accessible, as the directive requires.
Give priority to digital media. Websites, webshops, product pages, social media profiles and newsletters can be updated quickly – and these are precisely the channels a regulator, competitor or customer will look at first.
Schedule printed materials and packaging. Establish what you can still revise and reprint before 27 September, which stock will be used up by then, and where you need an interim solution.

What will run beyond 27 September – and how to manage it

A completely new LCA for a claim that is not yet substantiated. Depending on the complexity of the product and the availability of data, such an analysis takes several weeks to several months – and it must then be translated into a compliant claim, with the supporting documentation built up.
External verification for forward-looking claims: a legal requirement, with a lead time that generally extends beyond September.
Redesigning and reprinting packaging, labels or catalogues whose production and delivery times already run past the deadline – particularly for large print runs or where external printers are involved. Until the new packaging is available, you can sticker over or cover the claim.

The cost of doing nothing versus acting in phases

The penalties under EmpCo are well known: fines of up to 4 per cent of annual turnover or a minimum of €80,000, withdrawal of advertising, and potential loss of customers as retailers question their suppliers more closely. Any company that fails to act now runs a risk with every vague claim it retains.

There is an opposite risk, however: shutting down all sustainability communications out of caution. Greenhushing solves nothing – the claims disappear, but the substantiation problem remains – and it costs you the very story you want to tell customers and investors.

Setting priorities is the way through. Put right what you can now, and schedule what takes longer for the medium term.

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What Pantarein offers at this stage

Not sure where your claims appear, or where to start? Pantarein’s Greenwashing Scan gives you a rapid overview of where the greatest risks lie, which claims you can put right without new substantiation, and which will require a longer-term project.

The scan follows five steps – risk profile and relevance, review of content, check of substantiation and credibility, amendment and rewording, documentation – but at this stage the emphasis lies mainly on the first steps: gaining a quick view of priorities and the greatest risks, and dealing with the claims that can be reworded without new substantiation. Projects that do require an LCA are scheduled with a realistic timeline extending beyond 27 September, so that you know today where you stand.

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Would you like to know where you stand?

Arrange a no-obligation conversation with one of our experts this month at mail@pantarein.be. Together, we will look at which claims should take priority, what can be completed for your company before 27 September, and what follows after that.

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