---
title: "Green claims audit: how to choose a provider (EmpCo)\nWho verifies your green claims?"
description: "Lawyer, technical firm, ARPP or independent third party: who can audit your green claims for EmpCo, how to compare quotes and what a useful report looks like."
canonical: https://projetcelsius.com/en/blog/empco-green-claims-audit/
author: "Guillaume Pakula"
datePublished: 2026-10-15
dateModified: 2026-10-16
language: en
translationOf: https://projetcelsius.com/blog/audit-empco-choisir-prestataire/
---

# Green claims audit: how to choose a provider (EmpCo) Who verifies your green claims?

**Author**: Guillaume Pakula
**Published**: 2026-10-15
**Updated**: 2026-10-16
**Section**: Practical guide
**Canonical URL**: https://projetcelsius.com/en/blog/empco-green-claims-audit/
**French original**: https://projetcelsius.com/blog/audit-empco-choisir-prestataire/
**Source**: Projet Celsius (https://projetcelsius.com/en/), a climate strategy consultancy of engineers and PhDs based in Paris and Marseille.

> An **EmpCo audit** is entrusted to a firm able to **link each claim to its evidence**, with legal advice remaining a matter for a lawyer. No text requires a general audit: the directive requires an **independent third party** only for labels and commitments on future performance, but the company must be able to **substantiate each message** if the DGCCRF (the French consumer protection authority) asks for it. No public price list exists: the price follows the number of messages, media and pieces of evidence, and the lead time depends mainly on how quickly the documents are available.

## Key takeaways

- An **audit examines the evidence** behind messages; legal advice comes from a lawyer.
- **The directive requires an independent third party** for labels and future targets.
- **Compare 3 quotes on the same scope**: messages, evidence, rewording, review.
- A good report links **each message to its evidence** and to its new wording.

An "EmpCo audit" **is not a standardised service**: neither the [EU EmpCo directive](https://projetcelsius.com/en/blog/what-is-empco-directive/) (Empowering Consumers for the Green Transition) nor French law defines it. Directive (EU) 2024/825 requires an **independent third party** in only **2 cases**, a sustainability label and a commitment on future performance. For everything else, the company must be able to **substantiate each message** to the DGCCRF (the French consumer protection authority), and it is to prepare that evidence that it calls on a provider.

The right contact depends on what the message says and where it is published. A **mention printed on a carton**, a television spot, an in-house logo and a "net zero emissions by 2040" target call for **neither the same review nor the same third party**. The following sections cover these cases, then the choice of provider and what the provider must deliver.

## Audit, lawyer or third party: which do you need?

The directive covers any message, image, symbol, label or brand name that **states or suggests** a positive or zero effect on the environment, or a lower effect than other products. A green leaf on packaging is one, as is a sentence in a [corporate communication](https://projetcelsius.com/en/blog/empco-directive-green-claims-guide/), and [no company size](https://projetcelsius.com/en/blog/empco-who-is-affected/) is exempt from the rule.

### What an audit of green claims covers

A serious audit starts from the real materials: packaging, product sheets, website pages, campaigns, reports. For each message, it looks for **the document that supports it** and checks that it covers what the sentence states, on the right product, the right component, the right period and the right criterion. A [life cycle assessment (LCA)](https://projetcelsius.com/en/blog/product-carbon-footprint-lca-pef-cfp/), an emissions assessment, a recycled-content certificate and a supplier data sheet **do not prove the same thing**.

### The lawyer and the ARPP: 2 complementary views

In France, giving legal advice on a regular, paid basis is **reserved for professions qualified to do so**, lawyers first among them ([Law of 31 December 1971, Article 54](https://www.legifrance.gouv.fr/loda/id/JORFTEXT000000508793)). The technical firm examines the evidence, and **the lawyer provides the legal opinion**. The quote states which of the 2 handles each point.

The Autorité de régulation professionnelle de la publicité (ARPP), the French advertising industry's self-regulatory body, operates in a different area. **Every television advertisement** is submitted to it before broadcast, and it issues an opinion: favourable, to be amended or not to be broadcast ([ARPP, roles and missions](https://www.arpp.org/qui-sommes-nous/roles-et-missions/)). For other media, it advises its members and charges other advertisers **€520 excl. VAT** for one-off advice, covering at most 5 projects reviewed **within 72 working hours**. It judges the message against its Sustainable Development recommendation, **without redoing the technical analysis** of the evidence.

### The 2 cases where the directive requires an independent third party

The first case is the **sustainability label**. [Directive (EU) 2024/825](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024L0825) prohibits displaying one that is not based on a certification scheme or has not been established by a public authority (Annex I, point 2a). A certification scheme involves **checking by a third party** independent of the label owner. In the States that have transposed the directive, an in-house logo that nobody checks from outside can no longer be displayed since 27 September 2026. In France, the transposition bill, [adopted by the Senate on 18 February 2026](https://www.senat.fr/dossier-legislatif/pjl25-118.html) *(in French)*, is still awaiting the National Assembly.

The second case is the **commitment on future performance**, such as "net zero emissions by 2040". It must rest on a detailed and realistic plan, **regularly verified by an independent third-party expert** whose conclusions are public. The Commission specifies that **auditors or consulting firms** may play this role ([Commission questions and answers](https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_fr?filename=ECGT%20Directive%20FAQ_20260710_FR.pdf)). They must also not have written the [transition plan](https://projetcelsius.com/en/blog/climate-transition-plan-requirements/), the same rule as for the [critical review of an LCA (in French)](https://projetcelsius.com/blog/revue-critique-acv-choisir-expert-independant/) *(in French)* or the [verification of a carbon footprint assessment (in French)](https://projetcelsius.com/blog/bilan-carbone-interne-verification-tiers/) *(in French)*.

## Is it mandatory to have your green claims audited?

No, outside those 2 cases. The obligation relates to the outcome: **each claim must be accurate and capable of being justified**, and the DGCCRF may demand the supporting documents at any time.

### What the law already requires

French law does not wait for the transposition of EmpCo, which was due on 27 March 2026 and which [the National Assembly has not yet voted on](https://projetcelsius.com/en/blog/empco-application-dates/). Misleading commercial practice is an offence punishable by **2 years' imprisonment and a fine of €300,000**. The fine may be raised to **10% of average annual turnover**, or to **80% of the campaign expenditure** where the deception rests on an environmental claim ([Article L. 132-2 of the Consumer Code](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000049532070)).

Since 2022, the French anti-waste law has banned the mentions "biodegradable" and "environmentally friendly" **on a product** or its packaging, and [carbon neutrality](https://projetcelsius.com/en/blog/carbon-neutral-claims-what-companies-can-say/) has been **regulated in advertising** since 2023. A company that sells in Germany or Italy also falls under those countries' **new rules**, which have applied since 27 September 2026, as our article on [who checks green claims](https://projetcelsius.com/en/blog/empco-enforcement-authorities/) explains.

> No text requires you to have your claims audited, but each one must be capable of being justified on the day the DGCCRF asks.

### What inspections find

In 2023 and 2024, the DGCCRF inspected **more than 3,000 establishments** on their environmental claims, and **more than 15%** showed serious failings ([review of 1 October 2025](https://www.economie.gouv.fr/files/files/directions_services/dgccrf/media-document/cp-dgccrf-lutte-contre-ecoblanchiment-20251001.pdf)). Its investigators issued more than 500 warnings, **more than 430 injunctions** and more than 70 fines or official reports, for 3 recurring defects:

- **Blanket claims**, which suggest a benefit for the environment with no identified impact, such as "eco-responsible delivery", "green concrete block" or "preserving the planet".
- **Mentions with no supporting evidence**, such as "upcycled" on newly imported garments, or production described as decarbonised when the project had not been launched.
- **Labels claimed wrongly**, such as timber announced as mostly FSC (Forest Stewardship Council) certified when the certification covered only a minority of products.

The DGCCRF also describes evidence files that do not stand up: **commercial brochures from the supplier** presented as supporting documents, or certificates unrelated to the products and **expired since 2013** ([DGCCRF interview of 2023](https://www.economie.gouv.fr/dgccrf/actualites-dgccrf/nous-sommes-tres-vigilants-sur-la-justification-des-allegations-environnementales)). In July 2025, SHEIN agreed to a **settlement fine of €40 million**, partly because it could not substantiate its environmental claims, including a 25% reduction in its emissions ([DGCCRF press release](https://www.economie.gouv.fr/files/files/directions_services/dgccrf/media-document/cp-dgccrf-SHEIN-sanctionne-amende-40millions.pdf)).

## How do you choose the right provider?

The choice is made in **3 steps**: check the competence that is not negotiable, ask the questions that set providers apart, then rule out the promises that no audit can keep.

### What is not negotiable

The provider must know how to **read technical evidence** and say precisely what it allows you to write. A certificate for the cardboard of a carton covers neither the jar nor its pump, and an LCA limited to climate change does not justify "eco-friendly". This reading calls for **engineering competence** in life cycle assessment, carbon accounting or materials. It also calls for **knowledge of the texts** that set the vocabulary, such as the [declaration of conformity under the Packaging and Packaging Waste Regulation (PPWR)](https://projetcelsius.com/en/blog/ppwr-eu-declaration-of-conformity/) for packaging or the [environmental labelling](https://projetcelsius.com/en/blog/france-environmental-labelling-textiles/) rules for a garment.

### The questions to ask

5 questions set 2 or 3 firms apart in a single interview:

- Which **comparable engagement** have you carried out, on which products and media, and can you show an anonymised report line?
- **Who, by name,** will examine the technical evidence, and who will review the report before it is sent?
- How do you work with **our lawyer** or our legal department, and on which points do you refer to them?
- What do you do **when evidence is missing**: request the document from the supplier, propose a narrower sentence or recommend a study?
- Do you propose **replacement wording**, and do you review the corrected materials before they are printed or published?

The answers to the second and fourth questions set firms apart fastest. A firm that cannot **name the person** who will read your evidence, or that answers every missing document with a study to be quoted, will sell you time rather than a finished file.

### The warning signs

Some promises should give you pause, because no audit can keep them:

- The provider promises an **"EmpCo certificate"** for the company, whereas the directive provides for certification only for labels.
- It **guarantees compliance of the whole catalogue** after reviewing a few products, without saying how its reasoning extends to the other product references.
- It **proposes an LCA straight away** for every message, before looking at the existing evidence and at what each sentence states.
- It **would verify its own work**, a climate plan or a label that it built, whereas the directive requires an independent third party.

## How does an audit work, and at what price?

A full engagement follows **6 steps**, from the inventory of messages to the review of the corrected materials. Market offers do not all cover every step, which often makes **2 quotes incomparable** when you look only at the amount.

Producing new evidence is handled separately in every offer: an [LCA](https://projetcelsius.com/en/blog/lca-cost/) or a measurement takes weeks and **is priced separately**, after the audit has shown that it was missing.

### The quote

A readable quote breaks the work down into 4 items that can be compared from one firm to another:

- It sets the **scope examined** in product references, media and countries, and says how messages repeated from one product to another are handled.
- It lists the **supporting documents studied**, the planned exchanges with suppliers and what happens when a document does not arrive.
- It describes the **deliverable**: one report line per message, the proposed wording and the number of versions reviewed after correction.
- It prices separately the **exclusions**: legal advice, new studies and the independent verification of a label or a plan.

### Lead time and price

No public price list exists for these engagements, and [the price of an audit of a range's claims (in French)](https://projetcelsius.com/blog/prix-audit-allegations-environnementales/) *(in French)* is read item by item. **The price follows the time spent**, which depends less on the number of products than on the number of distinct messages, media and pieces of evidence to gather. **10 product references** that share the same mention and the same certificate are handled together, whereas a single product sold in 4 countries with 3 campaigns requires more.

The lead time depends mainly on **how quickly the documents are available**. A complete file is reviewed in a few days, whereas a file whose evidence comes from several suppliers takes weeks. Before a reprint, the schedule is set backwards from the **printer's proof sign-off**, and the quote states when the lead time starts to run.

## What does a useful audit report look like?

A useful report **can be read line by line**. For each message, it gives the medium, the published sentence, the document received, what it establishes, the text that applies and **the sentence the evidence allows you to write**. A **ranking by risk level**, without that last column, leaves the hardest part to the marketing team.

### 3 messages flagged by the DGCCRF, and what follows

The rewordings follow the [practical guide of the French National Consumer Council (CNC)](https://www.arpp.org/wp-content/uploads/2023/06/Guide-pratique-des-allegations-environnementales-du-CNC-2023.pdf) and the texts cited above. Here is what a report would propose for **3 messages that the DGCCRF flagged**:

- "Eco-responsible delivery" gives way to **the fact that the evidence establishes**, for example "Delivery by bicycle in Paris", because a general benefit must become an identified benefit.
- "Preserving the planet" **is removed**, because the directive prohibits the generic claim without recognised excellent environmental performance (Annex I, point 4a).
- "Upcycled" on newly imported garments **is removed**. If fabric offcuts are genuinely reused, the sentence says so, with the document that proves it.

### The most frequent gaps

From one file to the next, **the same gaps** between the message and its evidence come up:

- The evidence covers **one component**, the carton or the refill, while the sentence refers to the whole product.
- The certificate is **out of date**, or it covers a different production site from the one that made the product sold.
- An LCA limited to **climate change** is used as evidence for a general message, such as "eco-friendly".
- A **comparison** does not say what it compares with or on which criterion.
- A **[recycled plastic](https://projetcelsius.com/en/blog/ppwr-recycled-plastic-content-targets/) content rate** is announced without the certificate for the material purchased.

The [2023-2024 review by the ARPP and ADEME (the French Agency for Ecological Transition)](https://www.arpp.org/wp-content/uploads/2024/10/Bilan-ARPP-ADEME-Publicite-et-environnement-2023-2024-1.pdf) confirms this picture on the advertising side. Over 4 months at the end of 2023 and the start of 2024, **65 of the 1,015 advertisements** with an environmental argument were not compliant. **68%** of them used vocabulary that misleads the public, such as "positive impact" or "preserves the planet", and **46%** overstated the qualities of the product or the advertiser's actions. Our article on [banned claims](https://projetcelsius.com/en/blog/banned-environmental-claims-eu/) details the list.

## What should you prepare before the first call?

A useful first call can be prepared in an hour, with 4 items:

- Gather **3 to 5 representative materials**, printed or as mock-ups, with the website pages and campaigns that reuse the same messages.
- Count the **volume to be handled** in product references, media and countries of sale: this is what sets the working time.
- Collect the **supporting documents already available**, even partial ones, such as supplier data sheets, certificates, an LCA or the specification of a label.
- Give the **deadline that matters**, a reprint, a launch or a trade fair, and the names of your contacts in marketing, product and legal.

**Stock that has already been printed** is handled separately, including for a company subject to the [packaging regulation](https://projetcelsius.com/en/blog/ppwr-who-is-affected/). On 30 June 2026, the national consumer protection authorities, meeting in the European Consumer Protection Cooperation (CPC) network, agreed a common line. Before imposing penalties, they will take into account stock volumes, shelf life and the feasibility of a correction ([European Commission](https://ec.europa.eu/commission/presscorner/detail/en/mex_26_1487)). A website is corrected without waiting, a package at its next print run or with a sticker, without [destroying unsold goods](https://projetcelsius.com/en/blog/unsold-textiles-destruction-ban/).

For us at Projet Celsius, the useful question to put to a provider is "what sentence will you propose in its place?". An **audit that stops at the risks** leaves the company alone with the most delicate part. We examine the evidence behind the messages, whether an LCA, a [Bilan Carbone®](https://projetcelsius.com/en/blog/bilan-carbone-method-explained/) (the French carbon accounting method) or a supplier data sheet, and we propose the wording it supports as part of our [support on environmental claims](https://projetcelsius.com/en/services/environmental-claims-empco/). Legal advice remains that of your lawyer, and we never verify a plan or a label that we have built.

## Key takeaways

- No standard defines an EmpCo audit: it examines the evidence behind messages, without amounting to legal advice or certification.
- The directive requires an independent third party only for sustainability labels and commitments on future performance.
- The right provider reads technical evidence, says what it allows you to write and works with your lawyer.
- A comparable quote specifies the scope, the evidence examined, the wording proposed and the reviews included.
- A useful report links each message to its document, its finding and the sentence that can replace it.

To test a sentence before calling anyone, our [greenwashing test](https://projetcelsius.com/en/tools/test-greenwashing/) asks the 3 questions of the [PIF method](https://projetcelsius.com/en/blog/greenwashing-test-3-questions/) (from the French Précise, Intègre, Fondée: Precise, Honest, Substantiated). To build the file, see [how to prove a claim](https://projetcelsius.com/en/blog/green-claims-what-empco-bans/).

## Frequently asked questions

## Frequently asked questions

### Is an EmpCo audit mandatory?

No. No text requires a general audit of environmental claims. Directive (EU) 2024/825 requires an independent third party in 2 cases: the checking of a sustainability label and the verification of a plan that supports a commitment on future performance. For everything else, the company must be able to substantiate each claim if the DGCCRF asks for it.

### Do you need a lawyer or a technical firm to check your environmental claims?

Often the 2 together. The technical firm examines the evidence and says what it allows you to write; the lawyer provides the legal opinion, which the Law of 31 December 1971 reserves for professions qualified to give it. A good quote specifies who does what and how the 2 work together.

### Is there an EmpCo certification?

No. The directive provides for no certification of a company's compliance. It provides for certification schemes for sustainability labels, checked by a third party independent of the label owner. An offer of an "EmpCo certificate" should lead you to ask which standard and which checks it covers.

### How do you compare 2 quotes for an audit of green claims?

By asking 2 or 3 firms for a quote on the same scope, with the same items and the same exclusions. No public price list exists: the price follows working time, which depends on the number of distinct messages, media, countries and pieces of evidence to gather, more than on the number of products.

### Can the ARPP approve an environmental advertisement?

It gives an opinion before broadcast on every television advertisement, and gives advice on other media, reserved for its members or charged at €520 excl. VAT per one-off piece of advice to others. The one-off advice covers at most 5 projects, returned within 72 working hours. It judges the message against its Sustainable Development recommendation, without redoing the technical analysis of the evidence.

### What should you do about packaging that has already been printed?

On 30 June 2026, the national consumer protection authorities, meeting in the European CPC network, agreed a common line: before imposing penalties, they will take into account stocks, shelf life and the feasibility of a correction. Online messages are corrected without waiting; a package is corrected at its next print run or with a sticker, which means taking an inventory of stock.

## Sources

- European Parliament and Council, [Directive (EU) 2024/825 of 28 February 2024](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024L0825), EUR-Lex.
- European Commission, [questions and answers on Directive 2024/825](https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_fr?filename=ECGT%20Directive%20FAQ_20260710_FR.pdf), 22 September 2026 (PDF).
- European Commission, [position of the authorities on old stock](https://ec.europa.eu/commission/presscorner/detail/en/mex_26_1487), 30 June 2026.
- Consumer Code, [Article L. 132-2](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000049532070), Légifrance. The Légifrance pages are in French.
- Law No. 2020-105 of 10 February 2020, [Article 13, which creates Article L. 541-9-1 of the Environmental Code](https://www.legifrance.gouv.fr/jorf/id/JORFARTI000041553773), Légifrance.
- European Commission, [Decision 97/129/EC establishing the identification system for packaging materials](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31997D0129), EUR-Lex.
- Law No. 71-1130 of 31 December 1971, [Articles 54 and 60](https://www.legifrance.gouv.fr/loda/id/JORFTEXT000000508793), Légifrance.
- DGCCRF, [review of the 2023 and 2024 investigations into greenwashing](https://www.economie.gouv.fr/files/files/directions_services/dgccrf/media-document/cp-dgccrf-lutte-contre-ecoblanchiment-20251001.pdf), 1 October 2025 (PDF).
- DGCCRF, [sanction imposed on SHEIN](https://www.economie.gouv.fr/files/files/directions_services/dgccrf/media-document/cp-dgccrf-SHEIN-sanctionne-amende-40millions.pdf), 3 July 2025 (PDF).
- DGCCRF, [interview on the substantiation of environmental claims](https://www.economie.gouv.fr/dgccrf/actualites-dgccrf/nous-sommes-tres-vigilants-sur-la-justification-des-allegations-environnementales), 5 September 2023.
- French National Consumer Council (CNC), [practical guide to environmental claims](https://www.arpp.org/wp-content/uploads/2023/06/Guide-pratique-des-allegations-environnementales-du-CNC-2023.pdf), 2023 (PDF).
- ARPP, [roles and missions](https://www.arpp.org/qui-sommes-nous/roles-et-missions/) and [sustainable development advice](https://www.arpp.org/nous-consulter/conseildd/).
- ARPP, [Sustainable Development recommendation, version 3](https://www.arpp.org/nous-consulter/regles/regles-de-deontologie/developpement-durable/), in force since 1 August 2020.
- ARPP and ADEME, [Advertising and environment review 2023-2024](https://www.arpp.org/wp-content/uploads/2024/10/Bilan-ARPP-ADEME-Publicite-et-environnement-2023-2024-1.pdf), October 2024 (PDF).