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If your business uses words like “sustainable”, “eco-friendly” or “carbon neutral” in its marketing, there are some important changes you need to be aware of.
Yesterday, 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive (also known as EmpCo) became applicable. The new rules aim to make environmental claims more transparent, more reliable and easier for consumers to understand, while also tackling misleading green marketing.
But what does this actually mean for your business? Can you still call your products sustainable? What about carbon-neutral claims based on carbon credits? And do these rules apply to UK businesses?
In this article, we’ll go through what has changed, which words and claims to be careful with, and some practical steps you can take to make sure your environmental communications are accurate and compliant.
EmpCo is an EU directive designed to protect consumers from misleading environmental claims and help them make informed purchasing decisions. It updates existing EU consumer protection legislation, introducing specific rules around environmental marketing, sustainability labels, product durability and other claims that could give consumers a misleading impression of a product’s environmental impact.
The important thing to understand is that this is not just about stopping businesses from making false claims. It is also about stopping claims that are technically true but give consumers the wrong impression. For example, imagine a company sells a bottle of cleaning product in packaging made from 30% recycled plastic. Advertising it as “made from recycled materials” without explaining that this only applies to the packaging could lead customers to believe the product itself is made from recycled ingredients.
Under the new rules, the overall impression your marketing creates matters, not just whether individual words are technically correct. And this applies to more than just product labels. Websites, social media posts, advertising campaigns, product descriptions and sustainability reports used in consumer marketing can all be relevant.
One of the biggest changes is the introduction of specific restrictions on certain types of environmental claims. Below we'll look into some of the terms and practices businesses should be reviewing.
Words such as “green”, “environmentally friendly”, “eco-friendly” and “sustainable” are broad claims. Consumers may interpret them as meaning that a product has little or no negative environmental impact overall. That can be difficult to substantiate, especially when a product has environmental impacts at different stages of its life cycle, from raw material extraction and manufacturing to transport, use and disposal. For example, a clothing brand might use organic cotton but still have significant emissions from manufacturing and shipping. Calling the entire product “sustainable” based only on the cotton used could create a misleading impression.
This is particularly important for businesses using carbon credits as part of their sustainability strategy. From 27 September 2026, the directive prohibits claims that a product or service has a neutral, reduced or positive greenhouse gas impact when those claims are based on offsetting emissions outside the product’s value chain. This includes familiar phrases such as:
For example, imagine you sell a product that generates 100 kg of CO₂e throughout its life cycle. Your business purchases carbon credits to compensate for those emissions and then advertises the product as “carbon neutral”. Under the new EU rules, you cannot use that offset-based claim to suggest that the product itself has no climate impact.
This doesn't mean that businesses can no longer buy carbon credits or support climate projects. It means you need to be careful about how you communicate that investment.
EmpCo also introduces stricter requirements around sustainability labels.
A sustainability label is a voluntary trust mark or quality mark that communicates environmental or social characteristics of a product, process or business.
Under the new rules, environmental or sustainability labels based on certification schemes need to meet specific requirements. In particular, the scheme must be based on a certification system or established by a public authority. Certification schemes need to have transparent and publicly accessible requirements, independent third-party monitoring and a procedure for dealing with non-compliance. This is relevant if your business uses certification logos, sustainability badges or environmental seals on products and marketing materials.
For example, displaying a green leaf logo that your business created itself could give consumers the impression that the product has been independently certified. If that is not the case, you need to make sure the label does not mislead them.
Businesses often communicate environmental targets such as:
These claims can help communicate your sustainability strategy, but they need to be credible and supported by a clear plan. EmpCo restricts claims about future environmental performance when they are not supported by clear, objective and publicly available commitments.
This is one of the most important questions for UK businesses. Although the UK is no longer part of the EU, businesses selling to EU consumers may still need to comply with EmpCo. For example, if you are a UK-based retailer selling products directly to customers in France, Germany or Spain, you should review your environmental claims and check the requirements applicable to your sales in those markets. If your business only operates in the UK and does not market products or services to EU consumers, EmpCo does not automatically become part of UK law simply because it has come into force in the EU.
However, that doesn't mean UK businesses can make whatever environmental claims they want. The UK already has consumer protection rules covering misleading environmental claims, and the Competition and Markets Authority has published its own Green Claims Code. This applies to businesses making environmental claims to UK consumers, whether they are large companies or small businesses.
The UK's Digital Markets, Competition and Consumers Act 2024 (DMCC Act) introduced stronger enforcement powers for the CMA, which came into force on 6 April 2025.
The CMA can now take direct enforcement action against businesses that breach consumer protection law, without having to go through the courts first. Businesses may face fines of up to 10% of their worldwide turnover for relevant infringements, as well as other potential remedies and consumer compensation.
This means greenwashing isn't just a reputational risk. It can also create a significant financial and legal risk. And the risks aren't limited to large consumer brands. If your business makes claims about its environmental performance to customers, those claims need to be accurate, clear and supported by evidence.
If you operate in both markets, it now may be a good time to review your marketing against the relevant requirements in both jurisdictions.
For example, a UK business selling cosmetics through its own website to customers in the UK and EU might need to check:
It's worth noting that EmpCo is not a replacement for all existing consumer protection requirements. Businesses must still check the wider rules applicable to their products and marketing.
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