The EU Empowering Consumers for the Green Transition Directive (EmpCo) introduces stricter rules on environmental claims, sustainability labels and greenwashing. Since 27 September 2026, the new rules have applied across the EU through national implementing laws. For apparel and footwear brands, understanding these requirements is essential to making credible environmental claims and reducing compliance risks.
Key facts about the EmpCo Directive
Official name: Directive (EU) 2024/825 on empowering consumers for the green transition
Also known as: EmpCo Directive or ECGT Directive
Adopted: 28 February 2024
National transposition deadline: 27 March 2026
Application date: 27 September 2026
Who is affected: Businesses making environmental claims to consumers in the EU, including fashion brands and retailers
Main objective: To strengthen consumer protection against misleading environmental claims and unreliable sustainability labels
What is the EmpCo Directive?
The EmpCo Directive is an EU consumer protection law designed to tackle greenwashing and help consumers make more informed purchasing decisions. It amends the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD), introducing stricter requirements for environmental claims, sustainability labels and information about product durability and repairability. Both explicit and implicit claims are in scope.
For fashion brands, this means reviewing how environmental performance is communicated across product names, collection names, packaging, labels, e-commerce pages and marketing campaigns.
Terms such as “eco-friendly”, “green” and “sustainable” can no longer be used as generic environmental claims without the required substantiation. Claims about a specific environmental benefit may still be possible when they are clear, specific and adequately supported.
The Directive does not prohibit brands from communicating their sustainability progress. Instead, it raises the standard for how environmental benefits are presented and evidenced.
Read the official text of Directive (EU) 2024/825.
What are the main EmpCo requirements for fashion brands?
1. Generic environmental claims face stricter restrictions
The EmpCo Directive prohibits generic environmental claims where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.
Examples of generic claims include:
“Eco-friendly clothing”
“Green collection”
“Sustainable fashion”
“Environmentally conscious brand”
Using a disclaimer or adding a small amount of supporting information elsewhere does not automatically make a generic claim compliant.
Where a brand wants to communicate a specific benefit, it should make the claim precise and clear within the same medium. For example, a claim about recycled fibres should identify what material is recycled and the relevant proportion, where applicable, rather than implying that the entire product is environmentally superior.
What brands should do: Review generic environmental wording across all consumer-facing channels. Replace broad claims with specific, evidence-based statements where appropriate, and assess whether any generic claim meets the Directive’s recognised excellent environmental performance exception.
2. Sustainability labels must meet specific requirements
The Directive prohibits displaying sustainability labels that are not based on a certification scheme or established by public authorities.
This affects environmental labels, sustainability badges and similar visual indicators used on products, packaging and digital channels.
Brands should assess whether each label has a legitimate basis, whether its certification scheme meets the applicable requirements, and whether the way the label is presented could mislead consumers.
What brands should do: Create an inventory of sustainability labels and verify their legal basis, certification requirements, scope and supporting documentation.
3. Carbon offsetting cannot substantiate certain product climate claims
EmpCo prohibits making a claim, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive environmental impact in terms of greenhouse gas emissions.
For example, a fashion brand cannot rely on carbon offsetting alone to claim that a particular garment is “carbon neutral”.
This restriction applies to product-level claims and does not mean businesses can never communicate about their emissions-reduction efforts or climate initiatives. Such communications must nevertheless be accurate, appropriately substantiated and compliant with applicable rules.
What brands should do: Identify product-level climate claims that rely on offsets. Review the evidence behind emissions-reduction statements and distinguish actual reductions in a product’s value chain from offsetting activities.
4. Claims about an entire product or business must not exaggerate a specific benefit
The Directive addresses claims that concern an entire product or business when the claimed benefit relates only to a particular aspect.
For example, if one component contains recycled content, the claim should not create the impression that an entire garment, collection or brand is recycled.
The overall impression matters, including the wording, imagery and context in which a claim appears.
What brands should do: Check that the scope of each environmental claim matches the scope of the available evidence. Make clear whether a benefit relates to a material, component, product, collection or business operation.
5. Old stock is not automatically exempt
The EmpCo rules apply from 27 September 2026. Products manufactured, ordered, distributed or placed on retailers’ shelves before that date are not automatically exempt from the new requirements.
In June 2026, national consumer protection authorities participating in the Consumer Protection Cooperation (CPC) Network agreed on a common understanding for handling old-stock situations. The approach supports consistent and proportionate enforcement where businesses face genuine transitional difficulties and prove genuine efforts in aligning with EmpCo obligations. It does not create a general exemption or automatic grace period, but guides national authorities in assessing case-by-case.
Authorities may consider whether a trader has taken timely, good-faith steps to comply and adapt its business-to-consumer practices.
Read the European Commission’s guidance on sustainable consumption and old stock.
When does the EmpCo Directive apply?
The EmpCo Directive was adopted on 28 February 2024 and entered into force on 26 March 2024. Member States were required to transpose its provisions into national law by 27 March 2026, with the new rules applying from 27 September 2026.
Because EmpCo is a Directive rather than a Regulation, businesses must consider the national legislation implementing it in each relevant market. The Directive establishes a common EU framework, but national implementation, enforcement practices and applicable penalties can differ.
For brands selling across multiple EU countries, this creates an additional compliance challenge: a claim used across several markets may need to be assessed against the relevant national rules and their interpretation.
What brands should do: Monitor national transposition and enforcement developments in every EU market where products are sold. Confirm which national provisions apply rather than relying exclusively on the Directive’s text.
For the latest official information, consult the European Commission’s EmpCo and sustainable consumption guidance.
What are the penalties for non-compliance with EmpCo?
EmpCo strengthens the existing EU consumer protection framework rather than creating a standalone penalty system for every environmental claim.
Enforcement takes place under the applicable national consumer protection rules. The assessment of a potentially misleading practice depends on the relevant legal provisions and the circumstances, including whether the claim is likely to cause the average consumer to make a transactional decision they would not otherwise have made.
Under the existing consumer protection framework, the Omnibus Directive (EU) 2019/2161 requires Member States to provide for maximum fines of at least 4% of a trader’s annual turnover in the Member State or Member States concerned for certain widespread infringements with a Union dimension. The applicable sanction depends on the infringement and the relevant national legislation.
Brands should therefore assess not only whether an individual claim is defensible, but also whether their internal processes can identify and correct problematic claims consistently across products and markets.
Read Directive (EU) 2019/2161.
How can apparel and footwear brands prepare for EmpCo compliance?
Environmental claims are embedded throughout the fashion value chain, from fibre sourcing and manufacturing to packaging, product launches and retail marketing. A single claim may appear on a hangtag, product page, collection landing page, social media post and campaign visual.
A structured compliance process can help brands identify exposure and establish consistent standards for future communications.
EmpCo compliance checklist
1. Identify all environmental claims
Review product descriptions, product names, collection names, packaging, hangtags, care labels, websites, advertising and social media. Include imagery, colours and symbols where they contribute to an environmental message.
2. Support claims with appropriate evidence
Identify the evidence supporting each claim. Confirm that it is relevant to the wording, sufficiently robust and up to date. Ensure the scope of the claim does not exceed the scope of the evidence.
3. Assess sustainability labels and certifications
Verify the basis for every label or badge and confirm that it meets the applicable certification or public-authority requirements.
4. Assess product-level climate claims
Identify statements about carbon neutrality, reduced emissions or positive climate impact, particularly where these rely on offsetting. Review them against the specific restrictions introduced by EmpCo.
5. Review existing stock and packaging
Identify potentially affected products and materials already in circulation. Establish a documented approach to corrective action and monitor relevant national enforcement guidance.
6. Map national implementation requirements
Check the applicable legislation in each EU market where the brand operates. Record relevant differences in implementation, enforcement and penalties.
7. Establish internal governance
Define who can approve environmental claims, which evidence is required and how claims are reviewed before publication. Coordinate legal, sustainability, product, sourcing and marketing teams.
8. Monitor regulatory developments
Keep track of official guidance, national enforcement priorities and related EU sustainability legislation. Review policies and claims when the regulatory position changes.
EmpCo Directive: Frequently asked questions
What does EmpCo stand for?
EmpCo is short for the Empowering Consumers for the Green Transition Directive, formally Directive (EU) 2024/825. It is also commonly referred to as the ECGT Directive.
When did the EmpCo Directive start applying?
The rules introduced by the Directive apply from 27 September 2026. Member States were required to transpose the Directive into national law by 27 March 2026.
Does EmpCo apply to fashion brands?
Yes. EmpCo is relevant to apparel and footwear brands, manufacturers, retailers and other traders making environmental claims to EU consumers. Its requirements can affect product descriptions, collection names, sustainability labels, packaging, websites and marketing campaigns.
Can fashion brands still use the word “sustainable”?
The word is not prohibited in every possible context. However, generic environmental claims such as “sustainable” are prohibited unless the trader can demonstrate the recognised excellent environmental performance required by the Directive (e.g. Ecolabel certified). The inclusion of the word “sustainable” in specific, substantiated claims may remain possible where they meet the applicable requirements.
Are sustainability labels banned under EmpCo?
Not all sustainability labels are banned. The Directive prohibits displaying sustainability labels that are not based on a certification scheme or established by public authorities. Brands should verify that each label meets the applicable requirements before using it.
Does EmpCo apply to old stock?
Old stock is not automatically exempt. The CPC Network has issued a common understanding to support a proportionate enforcement approach in genuine transitional situations, but this does not create a general exemption or automatic grace period.
Is EmpCo the same as the Green Claims Directive?
No. EmpCo is Directive (EU) 2024/825, which amends existing EU consumer protection legislation. The proposed Green Claims Directive is a separate legislative initiative and should not be confused with the rules introduced by EmpCo.
How can a brand assess its EmpCo compliance?
A brand can start by auditing its environmental claims, verifying supporting evidence, reviewing sustainability labels, assessing product-level climate claims and checking the national laws applicable in its sales markets. A documented approval process and ongoing regulatory monitoring can help maintain compliance.
Need practical support with EmpCo compliance?
Understanding the EmpCo Directive is the first step. For brands, the next challenge is identifying which requirements apply to their business, where environmental claims may create compliance risks, and what actions to prioritise.
2B Policy’s Compliance Launchpad Services help brands turn regulatory requirements into practical next steps. Our EmpCo Launchpad provides a business-specific assessment of the regulation, a tailored report, an expert share-out and action planning, delivered within 2–4 weeks for a fixed fee of €4,400.
Whether you need to assess existing environmental claims, identify potential gaps or establish a clear compliance action plan, our team helps you move from regulatory uncertainty to operational execution.
Explore our EmpCo Compliance Launchpad to understand the service and take the next step towards EmpCo compliance.
Need support with EmpCo compliance? Contact the 2B Policy team to discuss your environmental claims, compliance priorities and regulatory monitoring needs.
Written by: Luisa Pellerano (Policy Analyst)
