The terms “green”, “sustainable” and “environmentally friendly” have become common elements of corporate communications in recent years. Under the European Union’s new rules, however, they will soon be subject to significantly stricter conditions.

The Empowering Consumers for the Green Transition Directive, or EmpCo for short, aims to ensure that consumers receive more accurate and verifiable information about the environmental characteristics of products and services. The new requirements will apply from 27 September 2026, leaving companies less than two months to prepare.

Which sustainability claims may become risky?

Under EmpCo, generic environmental claims that do not clearly specify what they refer to or what results or data support them will be subject to stricter scrutiny. Examples include:

• “environmentally friendly”;
• “green”;
• “sustainable”;
• “climate-friendly”;
• “eco-friendly”;
• “biodegradable”.

These claims may only be used in generic form if the company can demonstrate recognised excellent environmental performance relevant to the claim. If the precise meaning of the claim is presented clearly and prominently on the same communication medium, it may qualify as a specific environmental claim. However, its accuracy must still be supported by appropriate data.

Particular caution is required when using terms such as “climate-neutral” or “carbon-neutral”. Product-level claims based solely on the offsetting of greenhouse gas emissions will be prohibited under the new rules. Communications must be based on the product’s actual life-cycle impacts and the results achieved within the company’s own value chain.

Specific claims are coming to the fore

In the future, statements that clearly define the nature and extent of environmental performance will become increasingly important. For example:

• “100 percent of the plant’s electricity consumption comes from renewable sources.”
• “70 percent of the packaging is made from recycled materials.”
• “The amount of water used in production decreased by 18 percent between 2023 and 2025.”

These claims provide consumers with more precise information but may only be used safely if the underlying data, calculation methods and time-based comparisons can be verified.

Stricter expectations will also apply to future commitments. Communicating a climate or emissions reduction target may require clear, publicly available and verifiable commitments, measurable time-bound targets, a realistic implementation plan and independent expert verification.

Labels and visual elements must also be reviewed

The impact of EmpCo extends beyond advertising copy. As a general rule, sustainability labels may only be used if they are based on an appropriate certification scheme or have been established by a public authority. Companies’ own “green” logos and certification marks may therefore also need to be reviewed.

The overall effect of the communication also matters. Leaves, water droplets, images of nature and green colour schemes used on packaging or in advertisements may themselves suggest an environmental benefit. Therefore, in addition to textual claims, the visual presentation and the overall impression created in the consumer should also be assessed as part of the compliance review.

What should companies do now?

Preparation requires coordinated efforts from ESG, marketing, legal, compliance, procurement and business functions. As a first step, it is advisable to:

• identify environmental claims appearing on websites, in advertisements, on social media platforms, packaging and product materials;
• verify the data, calculations and methodologies supporting the claims;
• review the labels, logos and certificates being used;
• identify wording that is too generic or potentially misleading;
• establish an internal approval and documentation process for new environmental claims;
• prepare marketing and sales teams to apply the new requirements.

The review must also cover communications and packaging relating to products already on the market, as the requirements will also apply to existing products from 27 September 2026.

Trust can be measured in the details

EmpCo places substantiation at the heart of sustainability communications. Accurate, measurable and properly documented claims can reduce legal and reputational risks while providing consumers with more credible information.

Preparing for the new requirements is therefore a broader task than reviewing marketing communications: it also requires the alignment of data, processes and responsibilities. Companies that establish the internal systems needed to verify their sustainability claims in good time may find themselves in a more favourable position.