Directive (EU) 2024/825 on Empowering Consumers for the Green Transition
September 2026. Greenwashing will be penalised
From 27 September 2026, the new requirements of the EmpCo Directive apply with binding effect across the EU. It tightens the Directive on Unfair Commercial Practices and the Consumer Rights Directive with clear rules against greenwashing, unsubstantiated environmental claims and misleading sustainability labels. Any business that reaches consumers in the EU through advertising, product information or sustainability commitments is affected.
The first step towards EmpCo compliance is knowing which of your claims, labels and advertising already pose a risk today. EmpCo Check AI assesses claims from different sources in seconds for conformity with the new directive.
Core Requirements at a Glance
Environmental claims
General statements such as ‘climate-friendly’ or ‘green’ will only be permitted where they are based on a verifiably recognised environmental performance. Blanket advertising claims without substantiation are prohibited.
Sustainability labels
Own labels without an independent certification system are no longer permissible. Every label used must be based on a verified system with independent oversight.
Climate neutrality and offsetting
Claims relating to CO2 neutrality that rely solely on offset certificates are prohibited. The actual impact within the company’s own operations must take precedence.
Early obsolescence
Deliberately designing products with a shorter lifespan or inducing consumers to replace consumables prematurely constitutes an unfair commercial practice.
Durability and repairability
Prior to purchase, businesses must inform consumers about the statutory guarantee, any commercial durability guarantee and, where available, the repairability score.
Digital content and updates
Businesses that provide software updates must state the period for which they will be made available and must not present an update as necessary where it serves only to improve functional features.
Consequences of Non-Compliance
Fines
Infringements of the Directive on unfair commercial practices may attract significant financial penalties depending on national implementation; for cross-border infringements, at least four percent of annual turnover.
Third-party legal action
Consumer protection associations and competitors may take direct legal action against unsubstantiated environmental claims, often more quickly than any regulatory review.
Reputational risk
A greenwashing allegation that becomes public has a considerably longer lasting effect than the original fine and also undermines trust in a brand’s other sustainability claims.
Key Dates at a Glance
Unlike the PPWR, the EmpCo Directive does not take effect in stages over several years but at a small number of clear dates. Any business that misses 27 September 2026 is exposed to enforcement action in every EU Member State from that day.
The Future Response Model
Fast results
A conventional review of advertising copy, online shops and labels across all communication channels takes weeks. AI-supported analysis delivers an initial assessment in hours.
Scalable precision
Whether five or five hundred product pages, every claim is assessed against the same criteria and remains comparable across the entire product range.
Intelligent processing
Knowing which claims are at risk is the first step. The second is ensuring that new claims, labels or product copy do not go out unreviewed in the first place. AI-based solutions such as our EmpCo Check AI can handle exactly this.
Practical implementation
A legal assessment of claims is the last step in a long process chain. We help define clear responsibilities, internal approval rules and standards that make compliant communication a matter of routine.
Dominik Ehrenreich
Managing Director & Principal
Author profile
Dominik Ehrenreich, MA, CAIA, is a Managing Director and Principal at Future Response. Previously, at Accenture (2015–2026), he served as Principal Director, leading ESG transformation programs for DAX-listed corporations and mid-sized companies. He was also responsible for developing globally deployed AI solutions to automate data collection and regulatory reporting processes.
EmpCo - Clear Answers to Your Questions
Compliance requirements are complex and raise questions.
We provide direct, practical answers.