About the EmpCo Directive (a.k.a. ECGT)

The Empowering Consumers for the Green Transition Directive (EU) 2024/825, known as EmpCo, bans vague or misleading green claims in marketing to EU consumers, including by non-EU companies, from Sept. 27, 2026.
What is EmpCo/ECGT

What is the Empowering Consumers for the Green Transition (EmpCo) Directive?

The Empowering Consumers for the Green Transition Directive (EU) 2024/825, known as EmpCo, is an EU law that bans misleading environmental claims in consumer marketing, effective Sept. 27, 2026.

The Empowering Consumers for the Green Transition Directive (EU) 2024/825, known as EmpCo, strengthens EU consumer protection against greenwashing and other misleading sustainability practices. The new rules apply from Sept. 27, 2026.

Directive (EU) 2024/825 amends existing EU consumer law to address misleading environmental and social information, sustainability labels and certain practices related to product durability and circularity.

The European Parliament and Council adopted the Directive on Feb. 28, 2024.

Who must comply

Who must comply with the EmpCo directive?

Anyone selling to consumers in the EU

The Directive applies to business-to-consumer commercial practices in the EU. This means:

  • EU-based companies marketing products to EU consumers
  • Non-EU companies, whose products are marketed to EU consumers directly or via EU retailers
    A US brand selling through an EU retailer falls within scope for the claims and labels used in its EU-facing communications.

If sustainability claims or labels are used in EU-facing marketing, packaging or online communications, these rules are relevant.

Regulated Criteria

What does the Directive regulate?

Environmental and Social Claims

Under EmpCo, misleading information and certain unsupported environmental claims are prohibited. EmpCo sets rules for how companies communicate sustainability in four areas:

  • Environmental claims and characteristics (e.g. related to a product's composition or environmental performance)
  • Social responsibility (e.g. working conditions and other social aspects)
  • Durability and circularity (e.g. durability, reparability and recyclability)
  • Sustainability labels (e.g. voluntary trust marks, certification marks or equivalent labels based on environmental or social characteristics)

Generic or vague environmental claims such as "eco-friendly" or "sustainable" may be considered misleading unless they are clearly substantiated and explained.

 

Timing & Enforcement

When and how will the ECGT/EmpCo be enforced?

The rules apply from Sept. 27, 2026.
  • Feb. 28, 2024: The European Parliament and Council adopted Directive (EU) 2024/825
  • March 27, 2026: Deadline for EU Member States to adopt and publish national measures implementing the Directive
  • Sept. 27, 2026: The new rules apply and become enforceable through Member States’ consumer protection frameworks

What happens if a company does not comply?

National consumer protection authorities can take enforcement action against prohibited or misleading commercial practices. Penalties are established under Member State law and must be effective, proportionate and dissuasive.

For certain major cross-border infringements subject to coordinated EU enforcement, maximum fines must be at least 4% of the trader’s annual turnover in the Member State or Member States concerned. If turnover information is unavailable, the maximum fine must be at least €2 million. Member States may establish higher maximum penalties.

How to comply with EmpCo

Sustainability claims must be clear, accurate and supported by evidence appropriate to the claim.

For brands and retailers marketing products to EU consumers:

  • Sustainability claims must clearly communicate the specific environmental or social characteristic being claimed and be accurate for the product they describe
  • Sustainability labels may only be displayed if they are established by public authorities or based on a certification scheme that meets the directive's criteria, including independent third-party monitoring
    A qualifying certification scheme is open on fair, transparent and non-discriminatory terms to any company able to meet its requirements, develops those requirements with relevant experts and stakeholders, can suspend or withdraw the label for non-compliance and has compliance monitored by an independent third party whose competence is based on international, EU or national standards.
  • Environmental claims must not overstate their scope
    A claim about an entire product or business is prohibited when it concerns only one aspect of the product or one activity of the business.
  • Generic environmental claims such as "eco-friendly" or "sustainable" are prohibited unless the company can demonstrate recognized excellent environmental performance relevant to the claim
    Recognized excellent environmental performance means compliance with EU Ecolabel requirements, an officially recognized national/regional EN ISO 14024 type I ecolabel or top environmental performance under other applicable EU law. Broad claims such as "sustainable," "conscious" or "responsible" cannot rest on recognized excellent environmental performance alone because they also imply social characteristics.
  • Claims that a product has a neutral, reduced or positive environmental impact in terms of greenhouse gas emissions are prohibited when they are based on carbon offsetting
  • Claims about future environmental performance require clear, objective, publicly available and verifiable commitments with an independently monitored implementation plan with measurable, time-bound targets, regularly verified by an independent, third-party expert whose findings are made available to consumers

OEKO-TEX® & EmpCo

OEKO-TEX® certifications provide independent, third-party verification that brands can rely on when communicating specific product attributes. That is why OEKO-TEX® has strict, long-established rules for the use of its labels and claims, supported by clear labeling and communication guidance. Brands and retailers are responsible for ensuring that claims accurately reflect both the certification scope and the product itself.

Verified Product Claims and Informed Decisions

Independent Testing and Verification

The role of independent verification is to generate reliable data that brands can use to communicate accurately and in line with applicable regulatory and customer requirements.

Hohenstein provides independent testing, certification and technical expertise. Our data, test reports, certificates and labels support verified product claims and help ensure that sustainability communication is grounded in objective, third-party evidence.

Work with our experts

FAQ: EmpCo Directive Compliance

Does Directive (EU) 2024/825 apply to companies outside of the EU?

Yes. If products are marketed to EU consumers, directly or via EU retailers, the Directive can apply to the claims and labels used in EU-facing communications.

When does the EmpCo Directive apply?

Starting Sept. 27, 2026. The deadline for EU member states to transpose the directive into national law was March 27, 2026. National consumer protection authorities enforce the requirements.

Are generic claims like "eco-friendly" still allowed?

Generic environmental claims may be considered misleading unless they are clearly substantiated and explained.

Does the Directive cover social claims?

Yes. Directive (EU) 2024/825 also covers social claims, such as statements about working conditions or responsible production.

Does the Directive cover durability claims?

Yes, if durability is mentioned in connection with an environmental claim (e.g. "durability saves resources").

Does certification make a product compliant with the directive?

Certification can support compliance by providing independent, third party verification of specific product attributes. Compliance depends on how claims are worded and substantiated.

Is this the same as the Green Claims Directive?

No. EmpCo (Directive (EU) 2024/825) is adopted EU law, with Member States applying the new rules from Sept. 27, 2026.
The Green Claims Directive is a separate legislative proposal focused on the substantiation and communication of explicit environmental claims. Negotiations stalled in 2025 after the European Commission signaled its intention to withdraw the proposal. As of September 2026, the proposal has not been adopted. The European Parliament lists its status as “Awaiting Council's 1st reading position.”

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Ben Mead

Managing Director
Hohenstein Americas