EmpCo whitepaper

Four kinds of environmental claim that no longer work from 2026

The EmpCo Directive does not prohibit environmental claims. It prohibits four particular kinds: claims about the whole product that only apply to a part of it; vague assertions without measurable evidence; self-made labels without an independent certification scheme; and legal minimum requirements advertised as an outstanding achievement.

Where the pressure comes from

150

environmental claims were assessed in a European Commission study

53.3 %

of them contained vague, misleading or unsubstantiated information

27 Mar 2026

EU-wide transposition into national law

from 09/2026

environmental claims for products must be EmpCo-compliant

Summary only

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This page gives the key points. The document itself contains every source, derivation and piece of evidence in full.

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Pars pro toto

An environmental claim about the entire product although it only relates to one particular aspect. Example from the whitepaper: a shampoo bottle is advertised as “made from recycled material” although only the cap contains recyclate.

Unfounded and vague assertions

A general, undefined environmental claim without measurable evidence. Examples: “environmentally friendly”, “green”, “ecological”, “environmentally sound”.

Unfair self-declarations and fake labels

A sustainability label or logo that is not based on an independent certification scheme and was not introduced by public authorities.

Legal minimums presented as a distinction

Legal requirements such as the minimum use of recyclate are advertised as outstanding environmental performance, creating the false impression of particular commitment.

What to do

The whitepaper lists six steps: a complete claim check across advertising, social media, website, packaging and point of sale; risk analysis and prioritisation; obtaining robust evidence, where necessary from the supplier; establishing internal approval processes and minimum requirements; managing layouts and stock early; and training marketing, sales and purchasing.

Source: Environmental claims in the EU: Inventory and reliability assessment, Final report, © European Union, 2020 (Milieu Consulting / Ipsos)
As of: March 2026

Editorial responsibility: Malte Biss, Managing Director of flustix GmbH