EmpCo Directive 2026
From 27 September 2026, new rules apply to environmental claims, climate statements and sustainability labels in the EU consumer market.
EmpCo Directive 2026: Review Labels and Environmental Claims
Upload a label and IMERO AI identifies EmpCo-relevant claims, labels and design elements. Our expert team reviews the AI result before sending and provides prioritised recommendations for your next revision.
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EmpCo Directive: the key facts
EmpCo stands for "Empowering Consumers for the Green Transition". Directive (EU) 2024/825 tightens requirements for environmental communication to consumers and supplements rules on consumer information. Particularly important for labels are new rules on generic environmental claims, climate claims, sustainability labels, future commitments and comparisons.
26 March 2024
EU Directive enters into force
Directive (EU) 2024/825 entered into force.
27 March 2026
EU transposition deadline
EU member states were required to transpose the Directive into national law by this date. In many countries, transposition is still in progress.
27 September 2026
Application date
The new rules apply. Whether and how existing products are affected depends on national implementation.
What is the EmpCo Directive?
The EmpCo Directive is designed to better protect consumers from vague or misleading sustainability claims. It amends the EU Unfair Commercial Practices Directive and the Consumer Rights Directive. For manufacturers and brands, this means: an environmental claim is no longer judged solely on individual words. What matters is the overall impression created by text, labels, product name, colours, symbols, images and context.
For packaging, the following questions are now particularly important:
↬ Is the claim specific enough – or does it rely on terms like "green", "eco-friendly" or "sustainable"?
↬ Does the claim clearly refer to the product, the packaging, a component, a production step or the company?
↬ Is the necessary clarification clearly and prominently visible on the same medium?
↬ Is there robust, current evidence that matches the specific claim?
↬ Does a voluntary sustainability label meet the requirements of a public or independently verified system?
↬ Does the design, product name or imagery create an additional environmental impression?
EmpCo from 27 September 2026: What changes for labels?
Topic
What needs to be reviewed
Generic environmental terms
Blanket terms without clear, prominent qualification on the same medium receive the highest review priority.
Broad overall claims
A positive attribute of an individual component cannot simply be extended to the whole product or company.
Climate claims
Product-related claims of neutral, reduced or positive greenhouse gas impact may not be based on external compensation.
Sustainability labels
Voluntary labels must come from a public body or be based on an appropriate certification scheme with independent verification.
Future commitments
Goals require a clear, realistic and publicly accessible plan, measurable time-bound targets, resources and regular independent review.
Comparisons
Method, reference product, baseline, time period and update frequency must be transparent.
Product and brand names
Names such as "Eco", "Green" or "Climate Neutral" can function as environmental claims depending on context.
Design
Leaves, water drops, nature motifs and seal-like icons can reinforce the overall impression or themselves act as trust marks.
Which environmental claims and design elements are affected
EmpCo looks beyond the most prominent claim. For a robust inventory, you should capture all B2C touchpoints: front and back of packaging, lid, sleeve, product name, website, online shop, social media, displays and point of sale.
Priority 1
Compensation-based product claims
Examples: "climate neutral", "CO₂-neutral certified", "carbon offset", "reduced climate impact" – where the claim is based on offsets outside the value chain.
Priority 1
Generic environmental terms
Examples: "eco-friendly", "green", "ecological", "climate-friendly", "biodegradable", "bio-based", "energy-efficient".
Priority 1
Own or little-known labels
Self-designed leaves, stars, circles or badges with terms like "Green Choice" or "Better Planet".
Priority 2
Broad overall claims
Claims about the entire product or company where evidence covers only packaging, energy or a single raw material.
Priority 2
Future and target claims
Examples: "climate neutral by 2030", "plastic-free soon", "Net Zero 2040".
Priority 2
Comparative claims
Examples: "30% less plastic", "more climate-friendly than …", "better for the environment".
Priority 3
Implicit claims
Product name, green-blue colour palette, leaves, water drops, nature images or placement next to sustainability text.
How the check works
1
Upload label
Select PDF, JPG or PNG, specify product category and target market.
Result:
A clear next step rather than an unstructured list.
2
AI analysis
IMERO identifies EmpCo-relevant text and design elements and ranks them by review priority.
Result:
Structured findings by Priority 1, 2 and 3.
3
Expert review
A member of our expert team reviews the AI result, adds context and removes obvious false positives.
Result:
Expert-verified, prioritised findings.
4
Receive concrete recommendations
You receive flagged findings, reasoning, open review questions and suggestions for the next revision round.
Result:
A clear next step rather than an unstructured list.
What the label check includes
↬ Flagging of the most important EmpCo-relevant claims, labels and visual elements.
↬ Prioritisation by "review immediately", "review in context" and "monitor".
↬ Specific questions to be clarified internally or with IMERO.
↬ Note on full label review or translation if further labelling issues are visible.
↬ Hinweis auf die vollständige Etikettenprüfung oder Übersetzung, wenn weitere Kennzeichnungsthemen sichtbar werden.
You will receive feedback promptly by email.
Implementing the EmpCo Directive: the 7-step checklist
1
Capture all claims
Inventory packaging, product name, labels, icons, website, online shop, social media and POS. Include translations and country-specific variants.
Result: Claim list per SKU, market and medium.
2
Separate claim and reference object
Identify whether the claim refers to the product, packaging, material, ingredient, location, process or company.
Result: Clear scope per claim.
3
Set review priorities
Start with compensation-based product claims, generic terms and voluntary labels. Then move to broad claims, future commitments, comparisons and implicit signals.
Result: Processing order with responsible parties.
4
Build evidence file
Assign each claim a data source, method, time period, baseline, scope, owner and update date.
Result: Central claim evidence matrix.
5
Refine wording
Name the subject, share, baseline, comparison, time period and method. Place the core explanation clearly and prominently on the same medium.
Result: Revised claim plus brief justification.
6
Plan stock and artwork
Identify remaining stock, print dates and affected markets. Evaluate new print files, correction stickers and supplementary point-of-sale information as operational options.
Result: SKU and artwork migration plan before 27 September 2026.
7
Establish a repeatable review process
Anchor claim approvals between marketing, QM, procurement, sustainability, design and external partners. Define re-checks when data, suppliers or regulations change.
Result: Governance, approval steps and change log.
Formulating environmental claims concretely: examples for packaging
The following examples are not blanket recommendations. They show how a broad buzzword can become a verifiable, delimited claim. Whether the approach fits depends on the product, market, presentation and evidence.
Broad original wording
More precise approach
Review questions
"Eco-friendly packaging"
"The plastic packaging consists of 80% post-consumer recyclate, based on the weight of plastic components; as of March 2026."
Is the percentage documented? Which components are included? Is "post-consumer" defined?
"30% less plastic"
"30% less plastic per 500 ml bottle compared to our 2023 predecessor model, measured by packaging weight excluding cap."
State comparison product, fill volume, base year and measurement method.
"Sustainably produced"
"At [location] plant, 100% of purchased electricity came from renewable sources in 2025. Evidence and accounting approach: [link/QR]."
Do not extend to the whole product if only site electricity consumption is evidenced.
"Climate neutral through offsetting"
"We support the [name] climate protection project with [amount/volume]. Information on project, period and funding: [link/QR]."
Do not derive neutral or reduced product impact from external offsetting.
"Recyclable"
"The PET bottle was assessed for the German collection and sorting system using [method]; excluded are [components]. As of [date]."
Clarify target market, system, components, method and date.
Own "Green Choice" label
Use a precise factual statement instead of a self-created label – or demonstrate that the underlying system meets the requirements.
Is it a public label or an appropriate certification scheme? Are criteria and oversight publicly available?
"Vegan – better for the planet"
Communicate "vegan" as a product attribute separately. Only add an environmental claim with its own concrete statement and matching data.
Vegan/vegetarian can function as a sustainability claim depending on context.
Same-medium rule: what must appear directly on the pack?
A generic environmental claim does not become precise simply because a detailed website exists somewhere. The core claim must be clearly and prominently qualified on the same medium. A QR code can provide access to evidence, methodology and additional details, but does not automatically replace the brief qualification next to the claim.
Practical text formula
Subject + measurable property + baseline + comparison/basis + time period + method/source. Example: "20% less packaging weight than 2024, based on the 250 g pouch; method and date: [link/QR]."
Special topics in detail
Climate neutral, CO₂-neutral and offsetting under EmpCo
Product-related claims that a product has a neutral, reduced or positive climate impact are among the central EmpCo topics. The European Commission's FAQ cites "climate neutral", "CO2 neutral certified", "carbon positive", "climate net zero", "climate compensated", "reduced climate impact" and "limited CO2 footprint" as relevant examples.
↬ Clearly separate product impact from funding of external projects.
↬ Present real improvements within the product life cycle with scope, baseline, time period and method.
↬ Do not derive neutral or reduced product impact from offsets outside the value chain.
↬ Describe investments in environmental or climate projects transparently as such, without attributing an unsubstantiated product attribute to them.
↬ Consider company-level claims separately.
CROSS-SELL
Beyond EmpCo: review and translate labels for new markets
The EmpCo check focuses on environmental claims, sustainability labels and the associated overall impression. For market entry or a full artwork update, IMERO offers in-depth review of food and cosmetics labels as well as market-specific translations. Our AI accelerates the analysis; specialist experts review the result and support concrete changes.
↬ Label review for food and cosmetics.
↬ Review of mandatory information, claims, language and market-specific requirements.
↬ Translation of ingredients, warnings, mandatory texts and marketing content.
↬ Cross-market variant management and transparent documentation.
↬ Expert service or software support for internal QM teams.
Frequently asked questions about the EmpCo Directive
Is your label ready for EmpCo?
27 September 2026 is closer than a full artwork cycle might suggest. Upload a label now and receive a structured view of claims, labels and design elements – with AI analysis and expert review.
Planning multiple SKUs or target markets? Talk to IMERO about scalable review and translation of your labels.