Directive (EU) 2024/825, commonly referred to as the Empowering Consumers for the Green Transition Directive or EmpCo, addresses misleading environmental claims, unreliable sustainability labels and information that shapes consumers’ view of a product’s environmental performance. A useful preparation file maps each public claim to its object, comparison basis, evidence and page location; it is not a universal certificate or an automatic compliance conclusion.

1. Define the regulatory boundary first

EmpCo operates within EU consumer-protection law and focuses on consumer-facing commercial communications, including advertising, product pages, packaging, labels, names, symbols and environmental labels. It does not replace product-safety, chemicals, packaging, carbon-accounting or market-access rules. Those requirements must be assessed separately for the product, market and applicable instrument.

The Directive treats an environmental claim as a message or representation in a commercial communication that states or implies that a product, product category, brand or trader has a positive or zero environmental impact, causes less harm, or has improved its impact. Broad wording such as “green”, “eco-friendly”, “carbon friendly” or “sustainable” should not stand without a defined object and supporting basis.

2. Turn each claim into a reviewable record

  • Claim text: preserve the exact wording, icon, location, language, page version and date from the product page, packaging, label or advertisement.
  • Claim object: identify whether the claim concerns the whole product, a component, a material, packaging, a production stage, transport or the trader’s activities. Evidence for one part must not imply a benefit for the whole product.
  • Comparison basis: for “lower”, “improved” or similar comparisons, record the comparator, functional unit, system boundary, data period and calculation method.
  • Evidence trail: index the bill of materials, supplier declarations, measurement or calculation records, lifecycle or carbon-footprint methodology, and the link to the SKU, batch and responsible entity.
  • Limits and assumptions: record excluded parts, use conditions, geography, time period and assumptions. Keep relevant qualifications close to the claim rather than hiding them in a remote page.

3. Review broad wording and labels

Terms such as “eco-friendly”, “green”, “climate friendly”, “biodegradable”, “recycled” and “low carbon” can create an overall impression of environmental superiority. Where the evidence supports only a defined attribute, rewrite the statement to identify that attribute and its conditions. If the evidence covers only a component or material, state that scope in the same visual context.

Do not present a self-created leaf icon or a “sustainable” filter as an independent certification. For a third-party label, retain the label owner, scope, authorisation or use conditions, certificate or licence record, and the link to the product. A label does not replace an explanation of the specific claim and its evidence.

4. Maintain four practical tables

  • Claim register: SKU, channel, language, wording, claim object, page location, version and owner.
  • Evidence index: file name, issuing or supplying entity, covered SKU/material/batch, data boundary, date, version and storage reference.
  • Calculation and comparison log: functional unit, system boundary, input data, assumptions, exclusions, reviewer and reproducible steps.
  • Rewrite and release log: original wording, reason for change, qualification, approval note, release date and change triggers.

Recheck the relevant evidence when materials, suppliers, packaging, calculation methods or claim scope change. Do not assume one fixed validity period applies to every certificate, report or product.

5. Transition and internal review

Directive (EU) 2024/825 applies from 27 September 2026. In its 2026 information on old-stock situations, the European Commission notes that authorities may consider production, orders, packaging cycles and the feasibility of corrective measures in individual cases. That information is not a product-specific exemption. Businesses should review live pages, advertising, packaging and labels in line with their market transition plan and retain the reason for each change.

A claim register supports internal review; it cannot be used to state that a product has “passed”, is “certified” or will necessarily avoid questions from authorities, platforms or customers. The outcome depends on the facts, national implementation and the overall presentation assessed by the relevant authority.

Sources and limitations

The primary source is Directive (EU) 2024/825 on EUR-Lex, including its definition of environmental claims and provisions on generic environmental wording and environmental labels. Transition and old-stock context is taken from the European Commission’s Sustainable consumption actions page. This article is a preparation reference, not legal advice for a specific product, Member State or sales page.

Greenark (Shenzhen) Certification Co., Ltd. can help organise product, evidence and page-version review records. Whether further assessment is needed depends on the actual SKU, target market and wording used.