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Legally sound certification:
Get free adviceEmpCo whitepaper
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.
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
The full document
The document itself carries every source, derivation and piece of evidence in full, along with the diagrams and tables.
The complete whitepaper including the checklist is available in exchange for your contact details.
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.
A general, undefined environmental claim without measurable evidence. Examples: “environmentally friendly”, “green”, “ecological”, “environmentally sound”.
A sustainability label or logo that is not based on an independent certification scheme and was not introduced by public authorities.
Legal requirements such as the minimum use of recyclate are advertised as outstanding environmental performance, creating the false impression of particular commitment.
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.
Seven forms of evidence
Microplastic-free, recycled content, recyclability, PFAS-free, reduced plastic. Each trustmark stands for one verified property and a publicly available certification scheme.
In more detail
A European Commission study on greenwashing assessed 150 environmental claims across different products. 53.3 per cent of them were vague, misleading or unsubstantiated about the environmental properties, both in advertising and on the product itself. The source is the 2020 report „Environmental claims in the EU, Inventory and reliability assessment".
An environmental claim is a statement about environmentally relevant properties of a product or service. It can concern how a product is made, packaged, distributed, used, consumed and disposed of. Greenwashing is the same statement without sound evidence: communication that improves the outward picture while little concrete or measurable action stands behind it.
First: environmental claims only with clear, objective and verifiable commitments, substantiated through an independent certification system. Second: sustainability labels and self-made logos without a recognised certification scheme or a public authority behind them are prohibited. Third: without independent evidence from a certification programme the claim is banned. Fourth: a claim about the whole product is unlawful if it actually refers to one part of it.
EmpCo does not replace existing law. National rules against unfair competition that prohibit misleading advertising remain in force. Anyone exposed under the old law is not less exposed under the new directive.
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
More from us
Our own consumer studies, technical documents on new regulations and scientific derivations, all on one page.
Free claim check
From 27 September 2026, every environmental claim on a product or its packaging must be substantiated. Send us up to five of your claims and we will set out which of them hold, which need specifying and where independent evidence is required. You receive a signed test report as a PDF within two to three working days. Free of charge and without obligation.
