Research shows that almost one in three advertisements containing an environmental claim carries a risk of greenwashing – rarely out of bad faith, but because the bar has suddenly been set far higher than many companies realise.

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The EmpCo Directive (Directive 2024/825) is the most concrete tightening of the rules to date: it amends the Unfair Commercial Practices Directive (UCPD) and adds a series of explicit prohibitions. Generic environmental claims, self-devised labels, climate-neutrality claims based on offsetting and forward-looking claims without a verifiable plan are no longer permitted. The scope is broad: packaging, websites, advertising, social media – and even brand names that allude to sustainability.

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The UCPD has long been the legal framework for B2C communications, but it left considerable room for interpretation. EmpCo narrows that room: the prohibitions are specific and apply without any case-by-case assessment. This is important for companies that operate mainly in B2B: B2B communications can also fall within the scope of the UCPD if they reach consumers indirectly – through retail partners, public channels or brand communications.

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The consequences of non-compliance are real: fines of up to 4% of annual turnover, or a minimum of €100,000 in Belgium, forced withdrawal of products from the market and loss of access to retailers that make compliance a purchasing condition. The deadline is 27 September 2026.

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But compliance is also an opportunity. Companies that substantiate their claims properly and continue to communicate set themselves apart from competitors who choose to stay silent on sustainability out of caution.

Together with you, we build communications that stand up both legally and commercially.

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We work in four steps:

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1. Claim inventory and risk profile – Which (sustainability) claims does your company make, through which channels and in what context? We map the full landscape of your claims and identify where the urgency and the risks are greatest – based on your sector, volume exposure and the nature of the claims.
2. Assessment against EmpCo and Green Claims Framework – Every claim is assessed against the prohibited practices set out in the EmpCo Directive and against Pantarein's own Green Claims Framework: a claim must be accurate, specific, quantifiable, complete, material, verifiable and credible. The same applies to implicit claims conveyed through colours, imagery or logos.
3. Rewording and substantiation – We reword problematic claims so that they meet the EmpCo requirements while retaining their communicative power.
4. Claims framework and internal process – For organisations that want to work on responsible communications in a structural way, we help set up an internal framework and approval process: who assesses which claims, against which criteria, and with what documentation obligations?

Being ready for the EmpCo Directive starts with knowing where you stand. Depending on your situation, these are logical next steps:

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• Greenwashing Scan: Do you want to know quickly which of your current claims are at risk? Pantarein's Greenwashing Scan reviews your entire sustainability communications and delivers an action plan with rewordings and supporting documentation. → Discover the Greenwashing Scan
• ESG positioning & storytelling: Your claims are accurate – so what now? We help you build a sustainability story that sets you apart, that inspires and that is consistent across every channel.
• Product Carbon Footprint: Do you want to substantiate climate claims at product level with data? A PCF provides the emissions data that make specific, substantiated claims about product impact possible.
• Sustainability reporting and the CSRD: The EmpCo and CSRD directives reinforce each other. Organisations that report robustly on their sustainability performance also have the substantiation they need for credible external claims.