When does EmpCo apply?

EmpCo applies from 27 September 2026. That is not a date from which something can be applied for, it is the day the new prohibitions start to apply towards consumers.

The chain of dates

• 28 February 2024: Directive (EU) 2024/825 is adopted by Parliament and Council.
• 26 March 2024: It enters into force. At that point it binds the member states, not companies.
• 27 March 2026: Deadline for transposition into national law.
• 19 February 2026: In Germany the amendment to the Unfair Competition Act is promulgated in the Federal Law Gazette.
• 27 September 2026: The rules apply. That leaves two and a half years of preparation between adoption and application.

No general transition or sell-off period

The implementing act provides for no general transition or sell-off period. What counts is the commercial practice towards consumers, not the date of printing. The rules therefore expressly also cover packaging manufactured, ordered, distributed or placed on the shelf before the application date.

In June 2026 the national authorities in the European Consumer Protection Cooperation Network (CPC) published a common understanding on this. Enforcement may be phased where old stock gives rise to genuine and specific transitional difficulties, and practical constraints such as packaging cycles, stock volumes, orders already placed and long shelf lives may be taken into account. What is expected in return are all reasonable and proportionate efforts, evidenced by records showing what was done and when. That is not a sell-off period, and the paper is not binding either.

What the deadline means in practice

Anyone planning print production should allow several months. Artwork change, internal sign-off, a new print run and selling off remaining stock happen one after another, not in parallel. Claims online are the opposite case: they can be changed without lead time, which is why they come first in the authorities’ own list.

What comes after 27 September

EmpCo is not the end of the development. The Green Claims Directive is a separate act governing how environmental claims must be substantiated and verified in advance. It is not yet applicable and its timetable is open. Meeting the EmpCo requirements today works in the same direction. Everything on EmpCo.