Policy Brief – Navigating The EU EmpCo Directive [Directive (EU) 2024/825]

Green claims are no longer just marketing language. Under the EU’s Empowering Consumers for the Green Transition (EmpCo) Directive [Directive (EU) 2024/825], vague or unsubstantiated claims are at risk of being classified as unfair commercial practices. This Directive introduces sweeping changes to EU consumer protection laws aimed at combating greenwashing and misleading sustainability communications

Terms such as “eco-friendly”, “green”, “nature’s friend”, and “climate friendly” are effectively banned unless businesses can substantiate them with credible and third-party verifiable evidence.

Why This Matters?

The Directive’s reach extends far beyond European borders. Any business marketing or selling products and services within the EU must comply, regardless of where the business is established.

The Directive introduces stricter scrutiny over:

• Environmental claims
• Sustainability labels
• Carbon neutrality claims
• Product durability, repairability and lifecycle claims
• Future climate commitments and net-zero statements

Businesses may face increasing regulatory exposure where sustainability claims are vague, unsupported and exaggerated. Even product names, branding, colours, symbols and nature-related imagery may potentially be interpreted as environmental claims under the new rules.

Industries Expected to Face Heightened Scrutiny

While the EmpCo Directive is cross-sectoral, industries that heavily market sustainability as a competitive advantage are expected to face particular attention, including:

• Fashion & Textiles
• Cosmetics & Personal Care
• Food & Beverage
• Electronics & Home Appliances
• Packaging
• Energy

Enforcement is Closer Than Many Businesses Realise

EU member states must transpose the Directive into national law by 27 March 2026.

The rules become applicable across the EU from 27 September 2026.

Several jurisdictions have already begun implementation, with potential penalties including multi-million Euro fines, injunctions, product recalls, and reputational exposure.

What the Full Policy Brief Covers

The full policy brief explores:

• What the EmpCo Directive means in practice
• The types of claims likely to face heightened scrutiny
• Industries expected to be particularly impacted
• Emerging enforcement developments across EU member states

The Era of Greenwashing is Over

The EmpCo Directive signals a broader regulatory shift whereby sustainability claims are increasingly expected to be evidence-based, independently verifiable and capable of regulatory scrutiny. For many businesses, this may require a fundamental reassessment of how sustainability is marketed, communicated and substantiated.