Across the European Union, consumers are increasingly seeing products marketed with claims such as “green,” “eco-friendly,” “sustainable,” or “climate neutral.” Environmental claims are now commonly used on product packaging, websites, advertising, product descriptions, and other marketing communications.
The growing use of green claims reflects increasing consumer interest in sustainability and transparency. Consumers want to understand whether environmental claims have a clear basis and can be trusted.
At the same time, the use of environmental claims that are too broad, difficult to verify, unsupported by sufficient evidence, or potentially misleading has increased concerns about greenwashing.
To address these concerns, the European Union is strengthening consumer protection rules through the Empowering Consumers Directive (EmpCo Directive) as part of its broader efforts to support the transition toward a more sustainable economy.
For companies using environmental claims or sustainability labels, these changes are important because they may affect how sustainability information is communicated to consumers.
The Empowering Consumers Directive: What Is Changing?
The Empowering Consumers Directive strengthens requirements previously established under the Unfair Commercial Practices Directive (UCPD).
Misleading advertising, including misleading environmental claims, was already prohibited in the European Union. However, whether a claim was considered misleading could depend on the specific circumstances of each case.
The Empowering Consumers Directive introduces more specific requirements for green claims. The objective is to make enforcement more consistent while providing companies with clearer expectations for communicating the environmental characteristics of their products.
The new requirements will apply from September 27, 2026.
For companies, this means that the use of green claims, sustainability labels, and environmental performance information should be reviewed more carefully.
1. Generic Environmental Claims Will Be Restricted
One of the key changes under the Empowering Consumers Directive concerns generic environmental claims.
Claims such as “eco-friendly,” “green,” or other broad environmental terms cannot be used freely when they are not supported by recognized excellent environmental performance.
Companies must also clearly and prominently specify what the environmental claim refers to through the same communication medium.
In practice, companies should avoid broad environmental statements without explaining the specific environmental characteristic behind the claim.
For example, a statement such as:
“Our product is green.”
should provide clearer context about the specific environmental characteristic being communicated and the evidence supporting that claim.
This change is relevant not only to marketing teams but also to sustainability, compliance, product, legal, procurement, and brand management teams.
2. Sustainability Labels Must Be Based on a Certification Scheme or Public Authority
Another important change concerns sustainability labels.
Under the new requirements, certain sustainability labels must be based on a third-party certification scheme or established by public authorities.
This is particularly relevant for companies that use sustainability labels as part of their product communication.
Third-party certification provides an independent verification mechanism based on defined requirements and criteria. This means sustainability information is not solely dependent on claims made by the company itself.
Companies using self-developed sustainability labels or proprietary labels without independent verification should review how these labels are created and used.
The objective is to ensure that sustainability labels have a clear, transparent, and credible basis.
3. Stricter Rules for Carbon-Offsetting Claims
The Empowering Consumers Directive also introduces stricter requirements for environmental claims involving greenhouse gas offsetting.
Companies may not communicate that a product has a neutral, reduced, or positive environmental impact when such claims rely on greenhouse gas offsetting in ways prohibited by the applicable requirements.
This is particularly important because terms such as “carbon neutral” and “climate neutral” can create specific expectations about a product’s environmental impact.
Companies should therefore understand the basis of every environmental claim they use and ensure that their communications do not imply environmental benefits that go beyond the available evidence.
How Is the EmpCo Directive Related to Greenwashing?
One of the key objectives of these regulatory changes is to strengthen consumer protection against greenwashing.
Greenwashing can occur when a company’s communication creates the impression that a product, service, or business activity has better environmental performance than can actually be demonstrated.
Companies should therefore establish a clear connection between the claim, supporting evidence, verification, and communication:
Claim → Supporting Evidence → Verification → Clear Communication
The claim should have a relevant basis. Supporting evidence should be available, verification should be conducted where applicable, and the information presented to consumers should be clear.
This approach can help companies reduce the risk of using green claims that are overly broad or open to different interpretations.
For companies operating in or marketing products to the European Union, effective sustainability claims management is becoming increasingly relevant to compliance and risk management.
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How Does the Empowering Consumers Directive Relate to Sustainability Certification?
Changes to sustainability labels make sustainability certification and third-party certification increasingly relevant for companies seeking to demonstrate specific sustainability characteristics.
A certification scheme can provide a structured framework for verifying defined requirements.
However, certification does not automatically mean that all of a company’s marketing communications comply with applicable regulations.
Companies should still ensure that their certification logos, sustainability claims, and product information comply with:
- Certification scope
- Certification requirements
- Claim requirements
- Label usage requirements
- Applicable regulations
Certification should therefore be viewed as one element supporting the credibility of sustainability information, rather than a replacement for the company’s responsibility to ensure that its communications are appropriate and compliant.
How Does ISCC Support This Approach?
ISCC is an independent third-party certification scheme that provides certification systems for various sustainable supply chains and materials.
In the context of the Empowering Consumers Directive, ISCC provides guidance on how companies should use ISCC logos and sustainability claims.
ISCC provides guidance on logos and claims through ISCC Document 208 “Logos and Claims.”
When an ISCC logo or claim is used for finished goods, the communication should clearly explain what the logo or claim refers to.
This information may include:
- Raw material category
- Chain-of-custody option
- Certified component
- Certified percentage
This approach helps make sustainability communication more specific and provides clearer information about the characteristics that have actually been certified.
As a result, ISCC certification can serve as one element supporting companies in developing more structured and verifiable sustainability communications.
Why Is Third-Party Certification Becoming More Important?
Changes in European Union regulations indicate a shift away from broad environmental claims toward claims that are more specific, transparent, and verifiable.
For companies, this means sustainability communication is no longer only a marketing responsibility.
Environmental claims can involve multiple business functions, including:
- Sustainability
- Compliance
- Marketing
- Product management
- Procurement
- Legal
- Supply chain
- Brand management
Third-party certification can provide a more independent basis for verification when a company wants to demonstrate specific sustainability characteristics.
However, companies still need to understand the scope and limitations of certification and ensure that their claims accurately reflect the certification results and applicable requirements.
What Should Companies Prepare?
Companies using green claims or sustainability labels can begin reviewing their current practices before the new requirements take effect.
1. Review Environmental Claims
Identify all green claims used on packaging, websites, advertising, product descriptions, social media, and other marketing materials.
Review whether each claim has clear context and sufficient supporting evidence.
2. Evaluate Sustainability Labels
Review the basis of the sustainability labels currently being used and determine whether they are based on a third-party certification scheme or public authority.
3. Review Supporting Evidence
Ensure that each sustainability claim has relevant information and evidence to support the statement being communicated.
Good documentation can also help companies explain the basis of their environmental information.
4. Evaluate Generic Claims
Identify broad claims such as “green,” “eco-friendly,” or similar terms.
Then assess whether these claims have an appropriate basis and whether the relevant environmental characteristics are clearly communicated.
5. Review Certification Claims
If your company uses a certification logo or certification claim, ensure that its use complies with the requirements of the applicable certification scheme.
Pay attention to certification scope, certified components, applicable percentages, chain-of-custody options, and logo and claim requirements.
6. Strengthen Internal Controls
Coordinate marketing, sustainability, compliance, product, legal, procurement, and brand management teams so they have a consistent understanding of how environmental claims should be used.
Clear internal controls can help reduce the risk of unsupported or inappropriate claims.
What Does the Empowering Consumers Directive Mean for Companies?
The Empowering Consumers Directive demonstrates that the way companies communicate sustainability information to consumers is changing.
Companies can no longer rely solely on statements that a product is “green,” “sustainable,” or “eco-friendly.”
Environmental claims need clear context and should be supported by information that can be substantiated.
For companies using sustainability certification, these changes also provide an opportunity to ensure that certification, claims, labels, and supporting evidence are managed consistently.
With the right approach, companies can reduce the risk of greenwashing, improve transparency, and strengthen consumer confidence in their sustainability claims.
Prepare for Sustainability Certification and Green Claims with CBQA Global
The Empowering Consumers Directive means companies need to take a more structured approach to green claims, sustainability labels, and sustainability communication.
CBQA Global supports organizations seeking to understand sustainability certification, third-party certification, and ISCC certification based on their activities and supply chain requirements.
If your company is reviewing its green claims, evaluating sustainability labels, or considering ISCC Certification, the CBQA Global team can help you understand the relevant certification requirements and prepare for the certification process in a structured way.
Contact CBQA Global to discuss your company’s Sustainability Certification and ISCC Certification requirements.
Email: marketing@cbqaglobal.com
WhatsApp: 08118468777
