On September 27, 2026, the EU's Empowering Consumers for the Green Transition Directive (Directive (EU) 2024/825, often shortened to EmpCo or ECGT) becomes enforceable across all EU member states. EmpCo amends the EU's Unfair Commercial Practices Directive (UCPD) and Consumer Rights Directive (CRD) to outlaw a long list of sustainability marketing practices that have become routine in fashion and retail: generic claims like “eco-friendly” or “carbon neutral,” self-invented green badges, and future net-zero pledges with no plan behind them.
If your brand markets in the EU and makes any environmental claim, this directive is not optional reading. It is the law that decides whether your next campaign, hangtag, or product page is compliant or a liability.
EmpCo (Directive (EU) 2024/825) becomes applicable on September 27, 2026, banning unsubstantiated environmental claims, self-created sustainability labels, offset-only climate neutral claims, and vague durability or repairability marketing.
With the European Commission having announced its intention to withdraw the separate Green Claims Directive in June 2025, EmpCo is now the only EU-wide anti greenwashing law with a confirmed enforcement date.
This article covers what's banned, how the future performance and durability rules work, what enforcement and penalties look like, and how traceability data lets you substantiate the claims you keep making.
EmpCo is an EU directive that bans unsubstantiated or misleading environmental and durability claims by amending two existing consumer protection laws rather than creating a new stand-alone regime. The Unfair Commercial Practices Directive (UCPD) gets a new, detailed list of “unfair commercial practices” specific to sustainability marketing, and the Consumer Rights Directive (CRD) gets new pre-contractual information duties around durability, repairability, and software updates.
The timeline is fixed: the directive entered into force on March 26, 2024, EU member states had until March 27, 2026 to transpose it into national law, and it becomes applicable, meaning enforceable against your marketing, on September 27, 2026.
EmpCo matters more today because it is now the only binding EU law directly targeting greenwashing. The European Commission formally announced its intention to withdraw the separate Green Claims Directive proposal on June 20, 2025, following pushback from the European People's Party and concerns from SMEs about mandatory third-party verification burdens. That proposal would have set more detailed, EU-harmonized rules for how environmental claims and labels get verified.
With the Green Claims Directive shelved, EmpCo is the rulebook brands actually have to follow. It's less prescriptive about verification mechanics than the proposal, but it is real, it has a hard enforcement date, and it is backed by the UCPD's existing national enforcement infrastructure across all 27 member states.
EmpCo bans five categories of environmental claims that lack proper substantiation, and most brands are currently making at least one of them somewhere in their marketing.
EmpCo treats durability, repairability, and forward-looking climate pledges as their own category of risk, separate from point-in-time environmental claims. Under the CRD amendments, it's now a banned practice to claim a product is repairable when it isn't, to market features that deliberately limit a product's durability, or to withhold information about how a software update will affect a connected product's performance or lifespan, the planned obsolescence problem.
Future performance claims get the strictest treatment. A statement like “carbon neutral by 2030” is only allowed if it's backed by a clear, objective, publicly available, and verifiable commitment, an implementation plan with measurable and time-bound targets, and regular independent third-party verification of progress. A pledge on a sustainability page with no underlying plan is exactly the kind of claim EmpCo was written to eliminate.
Non-compliance is enforced at the national level through each member state's existing UCPD enforcement bodies, meaning your exposure will vary somewhat by country, but the EU-wide floor is significant. For widespread infringements, the UCPD framework sets penalties of at least 4% of the trader's annual turnover in the member states concerned, or a fixed alternative amount where turnover data isn't available1. Ireland's Competition and Consumer Protection Commission, for example, can issue compliance notices, fixed payment notices, and court prohibition orders in addition to the turnover-based fine.
The financial exposure is one problem. The reputational one may be bigger: a public enforcement action or prohibition order against a specific claim is precisely the kind of story that outlives the campaign it was attached to.
The common thread across every banned practice in EmpCo is a missing evidence trail. The directive doesn't ban sustainability marketing, it bans sustainability marketing that can't be proven at the level of the specific product, material, or claim being made. That's a data problem before it's a legal one.
This is where traceability infrastructure becomes the compliance layer, not just a supply chain tool. TrusTrace connects sustainability claims to the underlying supply chain data, certifications, material composition, and chain of custody records, so a claim like “made with recycled cotton” is backed by verifiable data down to the specific SKU rather than a brand-level marketing assertion. The question isn't whether your brand has a sustainability story to tell, it's whether you can prove it claim by claim, product by product, the moment a regulator or a customer asks.
For brands preparing for September 27, the practical starting point is a claim-by-claim audit: every environmental statement currently live in EU-facing marketing, matched against the evidence that would need to support it under EmpCo. TrusTrace's webinar on Navigating Green Claims and Digital Product Passport Compliance Solution both walk through how that evidence gets structured and attached at the product level.
No. The European Commission formally announced its intention to withdraw the Green Claims Directive proposal on June 20, 2025. The Empowering Consumers Directive (EmpCo, Directive (EU) 2024/825) is now the operative EU law on greenwashing.
EmpCo entered into force on March 26, 2024, and EU member states had until March 27, 2026 to transpose it into national law. It becomes applicable and enforceable against marketing practices on September 27, 2026.
Only with substantiation. Generic claims such as “eco-friendly,” “green,” or “nature positive” are banned unless the product can demonstrate recognized excellent environmental performance backing the claim.
Not for every claim. Sustainability labels specifically must be based on a certification scheme or established by a public authority and independently verified. General environmental claims require documented, verifiable proof, and future performance claims require regular independent third-party verification of progress.
EmpCo is enforced through each member state's national UCPD enforcement framework. For widespread infringements, penalties reach at least 4% of the trader's annual turnover in the member states concerned, alongside compliance notices, fixed payment notices, or court prohibition orders depending on the country.
TrusTrace helps brands and retailers connect sustainability claims to verifiable supply chain data, so every environmental statement you make in the EU market is backed by evidence at the product level, not just brand-level marketing copy. Learn more about TrusTrace's Product Claims Capabilities or speak with one of our experts about auditing your current claims before September 27, 2026.
Disclaimer: This content is for informational purposes only and does not constitute legal advice. Please consult legal professionals for guidance specific to your situation.