EmpCo Directive: What Companies Need to Know

Climate Claims, Carbon Credits and Climate Communication

©wahyuni | stock.adobe.com

From 27 September 2026, companies communicating sustainability efforts, climate action, or environmentally friendly products and services will face a new regulatory reality. On this date, the EU’s Empowering Consumers for the Green Transition Directive  (EmpCo) will take effect across the EU, reshaping how businesses communicate environmental commitments, sustainability achievements, and climate-related product benefits.

How the EmpCo Directive is Changing Climate Communication

The directive’s objective is clear: to better protect consumers from unclear or misleading environmental messaging and increase transparency around sustainability claims. For companies, this means significantly stricter requirements for environmental and climate-related communication, particularly with regard to verifiability and transparency. This applies to all types of claims and the use of labels and eco-labels.

For businesses, the implications could be substantial. Claims such as “climate-friendly,” “ecological,” “green,” or “sustainable”  will increasingly require clear, verifiable evidence. Unsupported or vaguely defined environmental messaging are no longer permissible under the new framework.

Moving From Generic Claims to Specific Information 

In practice, this means that general environmental slogans should increasingly be replaced by specific information—information that can be explained, documented, and, if necessary, substantiated.

Example:

❌ "Climate-friendly packaging"

This type of statement is very general, leaves too much room for interpretation and is, therefore, not permissible.

✅ "100% of the electricity used to produce this packaging comes from renewable energy sources."

This statement provides specific, measurable, and verifiable information that allows consumers to understand the environmental benefit being claimed.

How Companies Should Prepare

Environmental claims are likely to come under much closer scrutiny from consumer protection bodies, NGOs, and competitors, making a proactive review of sustainability-related communication increasingly important.  Companies should therefore proactively assess which claims, labels, and marketing materials they currently use and in which context.

“Rather than waiting for enforcement actions, companies should proactively assess where the EmpCo Directive may affect their communications. A structured review of existing claims, labels, and marketing materials is often the most effective first step towards compliance.”

Susanne Peindl

Managing Director and Legal Counsel First Climate

Importantly, the impact of EmpCo goes far beyond individual sustainability claims. Companies should also assess packaging design, colors, imagery, labels, symbols, and even product or brand names where these could be interpreted as environmental messaging. Because the EmpCo Directive takes a broad view of environmental communication, its implications may extend across marketing, branding, and product positioning.

For companies, the message is simple: now is the time to act. Businesses should review consumer-facing communications and adapt them where necessary before the new requirements take full effect.

Can Companies Still Communicate Climate Action Once EmpCo Takes Effect?

In short: yes – but in different ways than before.

One important distinction under the EmpCo Directive is between product-related environmental claims and broader corporate sustainability communication.

Product-level claims such as “climate neutral”, or “CO₂-neutral”  are no longer allowed, especially with regards to the purchase of carbon credits. The key factor is the impact of the message: Consumers must not be led to believe that a product has a neutral or positive environmental impact simply because carbon credits were purchased or retired.

At the same time, communicating about voluntary climate financing and support for high-quality emissions reduction or carbon removal projects remains both possible and important.

In this sense, EmpCo does not represent a complete break with previous developments, but rather continues a discussion that has been shaping the voluntary carbon market for years: climate action communication must become more transparent, more concrete, and more verifiable. This also includes avoiding broad claims of carbon neutrality when these are based solely on carbon credits,

First Climate has recommended over the last several years that companies shift their focus away from product-related neutrality claims and move toward more transparent forms of direct climate finance and contribution-based communication. At the same time, under the EmpCo, existing communication formats, labels, and verification mechanisms must also be reassessed and, where necessary, further developed.

The key question is not, “Can we talk about climate action?” but rather, “How can we communicate it in a transparent, accurate, and reliable way?”

As a result, the focus of climate communication is likely to shift towards more comprehensive and more transparent explanations of climate strategies, emissions reduction efforts, climate contributions, and voluntary commitments beyond regulatory requirements.

More about EmpCo

How can companies communicate their commitment to climate action under the EmpCo framework?

The Directive defines primarily which statements will no longer be permited—or at least only permitted under certain conditions. It is less clear how companies should specifically communicate their climate and sustainability commitments in the future in order to comply with EmpCo. Many questions regarding EmpCo in practice currently leave room for interpretation and are likely to be clarified only through regulatory practice and case law in specific instances.

As a result, it is currently difficult to derive reliable recommendations for all specific use cases. Companies are well advised to craft their climate and sustainability communications with particular care and, when in doubt, to err on the side of caution in their wording. It is crucial that statements be specific, transparent, comprehensible, and verifiable for consumers.

When communicating carbon credits, for example, details regarding the projects supported are particularly helpful: the standards applied, the scope of financing, the intended use of carbon credits, and the role of these contributions within the overarching climate strategy.

What will happen to environmental labels and sustainability seals under EmpCo?

The EmpCo guideline does not apply only to written environmental claims. These requirements also apply to environmental labels, seals, and certification logos used in consumer-facing communications. Sustainability labels may generally be used only if they have been introduced by a public authority or are based on a certification system that provides transparent criteria and independent external monitoring.

For companies, this means that labels, seals, or label-like symbols that do not meet these requirements should no longer be used in consumer-facing communications. What matters is not merely whether a label is well explained, but whether it structurally complies with the requirements of the EmpCo Directive.

Companies should therefore seriously assess all logos, seals, icons, badges, and certification marks used in their communications. This is because visual elements can also be interpreted as environmental claims or sustainability labels if they suggest to consumers a specific environmental performance or sustainability benefits.

What does this mean for First Climate's "Supporting Climate Action" Label?

Following the entry into force of the EmpCo Directive, First Climate will not issue the existing “Supporting Climate Action” label again until further notice.

With this decision, First Climate is taking into account the fact that the specific application of the new requirements will only become clearer in the coming months. During this phase, we want to ensure that communication solutions for our clients are not only transparent and credible but also regulatory-compliant in the long term.

This does not mean that climate protection contributions or voluntary climate financing are losing importance. Rather, it means that communication must be structured even more precisely, transparently, and in a manner that is robust from a regulatory perspective in the future.

With this in mind, First Climate is actively working on solutions that meet the new requirements and will continue to enable our clients to communicate their climate commitments in a transparent, credible, and regulatory-compliant manner.

Download Our EmpCo Checklist!

Need some more guidance on EmpCo?

Download your exclusive EmpCo information here.