What the EU's EmpCo Directive Means for Environmental Claims in Logistics
From 27 September 2026, a new set of EU rules changes what companies can say about the environmental performance of their products, services, and operations. If your organization communicates about emissions reductions, sustainability initiatives, or climate performance – whether to partners, customers, or the wider market – it's worth knowing what's changing.
What is EmpCo?
The EU's “Empowering Consumers for the Green Transition” Directive (EU) 2024/825, known as EmpCo, entered into force in March 2024 and applies EU-wide from 27 September 2026. In Germany, it is implemented through amendments to the UWG (Gesetz gegen den unlauteren Wettbewerb); other member states are transposing it into their own competition or consumer protection law.
Worth noting: EmpCo is a separate, already-settled piece of legislation from the proposed Green Claims Directive, which the European Commission moved to withdraw in mid-2025 and whose future remains open. EmpCo is unaffected by that and is proceeding as planned.
What changes
EmpCo tightens the rules around several types of environmental claims:
- General claims like “eco-friendly,” “green,” or “sustainable” must be specified with clear, evidenced criteria wherever they're used – vague, unqualified claims are considered misleading.
- Comparative claims (“reduced,” “better,” “lower footprint”) need a clearly stated baseline, system boundary, and supporting data.
- Product-level claims of “climate neutral” or “CO₂-neutral” that rely on offsetting outside a product's own value chain are restricted; the focus shifts to actual reduction and decarbonization rather than compensation framed as an end state.
- Future-facing claims (targets, “net zero by…”) need a public, verifiable implementation plan with interim milestones and independent review – not just an announced ambition.
- Sustainability labels must be based on either a government scheme or a third-party certification system open to all businesses; self-created “eco” seals no longer qualify.
What this means in practice
None of this is new in spirit – it formalizes what's already good practice in credible environmental communication: say only what you can prove, be specific about scope and baseline, and don't let compensation stand in for actual reduction. Companies that already document their emissions data with a clear methodology and system boundary – as is standard in supply chain and logistics emissions accounting under frameworks like the GLEC Framework and ISO 14083 – are typically well positioned for these requirements.
The practical takeaway: it's a good moment to review how your organization talks about emissions reductions and climate targets, both externally and internally, and check that specific figures are backed by a clear baseline and methodology. Because the assessment of individual claims depends heavily on the specific wording and context, we would recommend involving legal counsel for anything you are unsure about – this article is meant as a factual overview, not legal advice.
