What is the difference between EmpCo and the Green Claims Directive?

They are two separate legal acts, and only one of them already applies.

EmpCo, Directive (EU) 2024/825, is transposed and applies from 27 September 2026. It prohibits certain practices: six entries on the blacklist of the German Unfair Competition Act plus three tightenings in the operative text. It requires no procedure before advertising; it creates a risk afterwards, enforced through warning letters and litigation.

The Green Claims Directive is a separate proposal. It would govern how explicit environmental claims must be substantiated and verified in advance, that is with prior verification by independent bodies and a certificate of conformity before the claim is used at all. It is not applicable at present and its timetable is open.

The difference in one sentence

EmpCo says what may no longer be claimed. The Green Claims Directive would say how what is claimed must be proven.

What that means for planning

Today the measure is EmpCo. Anyone moving their claims onto independently verified evidence now also meets what the Green Claims Directive would require, because both run in the same direction: verifiable rather than asserted. The work is the same in either case, namely answering for every claim who assessed it and where that can be looked up.

A third act belongs beside them because it is often confused with these two: the PPWR governs packaging itself, that is substances, recyclability and recycled content, not the advertising of it. Meeting a PPWR requirement therefore does not automatically allow you to advertise it; advertising it brings you under EmpCo.