Understanding EmpCo, the anti-greenwashing directive
in 2 minutes

EmpCo builds on the oldest rule of consumer law, the ban on misleading customers, and adds a list of green claims that are prohibited in principle, without requiring a judge to establish that anyone was misled.

This guide explains the abbreviation, the mechanism, the practices covered, the scope and the timeline, and what you can still say.

1Where EmpCo comes from and which legislation it amends

Its full name is Empowering Consumers for the Green Transition, Directive (EU) 2024/825, adopted on 28 February 2024. The same text goes by 3 names: EmpCo among consultants and marketers, ECGT in Commission documents and 2024/825 among lawyers.

EmpCo amends 2 existing texts. It adds to the blacklist in the Unfair Commercial Practices Directive of 2005 a series of green claims now prohibited (in French) in all circumstances. In France, the corresponding offence is a misleading commercial practice, the main basis for action by the DGCCRF (the French consumer protection authority). It also amends the Consumer Rights Directive on information about durability, repairability and guarantees.

Normally, penalising misleading advertising requires proof that an average consumer could have been misled. A blacklisted practice does not require that proof: it is prohibited in all circumstances.

2EmpCo blacklists claims and regulates future promises

For environmental messages, the text blacklists 4 practices and regulates others, together forming 3 groups.

Words that promise without evidence

"Eco-friendly", "green" and "sustainable" used on their own become prohibited, unless they reflect recognised excellent environmental performance: an EU Ecolabel or an officially recognised ISO 14024 Type I ecolabel. "Eco-responsible" water no longer complies, nor does a "responsible" T-shirt, even with calculated environmental labelling: you can display the score itself. Self-created labels based on neither certification nor a public authority are also covered, as are claims that extend a claim about part of a product to the whole product, such as a "recycled bottle" presented as an "eco-friendly product". Precise, quantified facts remain permitted: "80% recycled material, supported by a certificate".

Legal requirements cannot be presented as voluntary advantages

Presenting a legal requirement as an advantage becomes prohibited: "phosphate-free" on a detergent when phosphates have been banned for years, or a repairability index promoted as a voluntary commitment when it is mandatory. The text also covers false promises about durability or repairability, and certain practices relating to software updates and consumables. You can still highlight an effort that goes beyond the requirement, backed by figures.

Future commitments need credible plans

A future commitment without a credible plan, such as "zero carbon by 2040" without a pathway or milestones verified by a third party, becomes a misleading practice. The most far-reaching measure targets offset-based neutrality: a flight, delivery or product advertised as "carbon neutral" because its emissions are supposedly "offset" by credits bought outside the value chain (in French) becomes prohibited in all circumstances. What remains possible is an actual reduction, measured through a Bilan Carbone® assessment covering scopes 1-2-3 (in French) (the French carbon accounting method), with the carbon contribution shown separately.

The same requirement runs through all these practices: each claim must rest on accessible, verifiable evidence matching the depth of the claim.

3EmpCo covers consumer-facing claims, with no size threshold

For the environmental provisions, 2 questions establish whether you are in scope, and neither turnover nor workforce size determines the answer.

2 conditions apply, regardless of company size

EmpCo's rules on environmental claims apply when 2 conditions are met at the same time:

• you address individual consumers (business-to-consumer, B2C), through an online shop, a physical shop, a product on a shelf or advertising aimed at the general public;
• your message relates to the environment, through a word ("green", "sustainable"), a visual (a leaf, the colour green), a label or sometimes even the product's name.

If the 2 conditions are met, you are in scope whatever your size: a small or medium-sized enterprise (SME) with 8 employees faces the same rules as a listed group. This is the major difference from the Corporate Sustainability Reporting Directive (CSRD), which will cover only companies with more than 1,000 employees and more than €450 million in turnover once Omnibus Directive (EU) 2026/470 is transposed. The directive also extends beyond green claims: alongside false promises about durability and repairability, it requires every business-to-consumer (B2C) seller to provide a harmonised notice on the legal guarantee and a harmonised label for any commercial guarantee of durability that the producer offers free of charge beyond 2 years. An online retailer making no green claims is therefore affected, in France upon transposition. The sector-by-sector test works through the borderline cases.

The timeline and France's delay

2 dates define the timeline:

• 27 March 2026 was the deadline for transposing the directive into French law. France did not do so, and the Commission sent it a letter of formal notice, along with 19 other States, on 28 May 2026.
• Since 27 September 2026, the application date set by the directive, EmpCo has applied in countries that have transposed it. In France, the new prohibitions will apply with the transposing law, adopted by the Senate on 18 February 2026 and still not examined by the National Assembly.

You might assume there is no risk until the French law is passed, but this reasoning fails for 2 reasons. First, existing French law on misleading commercial practices and the AGEC law (France's Anti-Waste and Circular Economy Act) already penalise most of these practices. Second, a judge hearing a dispute reads French law in the light of the directive, through consistent interpretation, and a competitor or association may rely on that interpretation. Until it is transposed, the directive does not by itself create a new prohibition between a company and its customers, but a claim it prohibits is already vulnerable under current law.

B2B companies are indirectly affected

A supplier selling only to other businesses, business-to-business (B2B), is not directly covered by EmpCo, although French law on misleading commercial practices also applies between businesses. The demand for evidence also reaches it through 3 channels:

• your clients subject to the CSRD report emissions from their value chain, including some of yours (their scope 3 (in French)), and request verifiable carbon data, whose absence may affect supplier approval;
• in public procurement, a claim you cannot substantiate leaves a requirement unmet in the tender, and an incomplete submission is rejected;
• private-sector clients require evidence from their suppliers to support their claims, so that their own B2C communications withstand scrutiny under EmpCo.

Suppliers that have not built their evidence base (in French) risk losing contracts to those that have.

4EmpCo operates alongside other environmental rules

5 frameworks overlap and are often confused:

Glossary

What are "green claims"?

Tennaxia definition

A generic term for any written or visual environmental claim a brand makes about a product, in advertising or on a website. The Green Claims Directive, a European proposal from 2023 currently suspended, would complement EmpCo by requiring prior third-party verification.

• EmpCo sets the general anti-greenwashing rule for B2C; it has applied since 27 September 2026 in countries that have transposed it.
• The Green Claims Directive, a separate proposal requiring third-party verification before publication, has been suspended since summer 2025 without being withdrawn: it must not be presented as forthcoming legislation.
• The AGEC law already bans certain words in France ("biodegradable", "environmentally friendly").
• The CSRD governs sustainability reporting by large companies and channels requests for data back to their suppliers.
• Environmental labelling (in French) (in French) and the Packaging and Packaging Waste Regulation (PPWR) provide sector-specific frameworks.

EmpCo sets out what you can no longer claim; the other texts explain how to substantiate claims or who must publish data. The complete map of the frameworks explains each one.

5Precise claims require evidence that covers their scope

Environmental claims remain possible, provided they are precise: replace the adjective with a quantified fact. "Eco-friendly" becomes "80% recycled cotton, made in France, supported by certificates". You can still communicate a measured reduction if the carbon contribution is shown separately, for what it is, and never presented as neutrality. To screen your wording before publication, the PIF method (in French), Precise, Honest, Substantiated (Précise, Intègre, Fondée in French), provides a 3-question framework.

Work through the task in this order:

• Take an inventory of active claims, including old pages still online (the greenwashing test identifies wording at risk).
• Remove wording that no evidence can support (offset-based neutrality, generic terms used alone, self-created labels).
• Document each remaining claim in an individual evidence sheet (in French) kept on file.

6Key takeaways

• EmpCo, ECGT and Directive (EU) 2024/825 refer to the same text, which blacklists several forms of greenwashing as unfair practices, without requiring proof that a customer was misled.
• 4 environmental practices join the blacklist, from offset-based neutrality to self-created labels, alongside presenting a legal requirement as an advantage and false promises about durability and repairability.
• There is no size threshold, and France's delay does not protect companies: current law already imposes penalties.
• Each claim must rest on evidence matching the depth of the claim: a carbon measurement (Bilan Carbone® or a product footprint) for a climate claim, a multi-criteria LCA for a broad claim.

At Projet Celsius, we see EmpCo as a welcome clarification: by banning offset-based neutrality, the text settles an issue we have long discussed, that corporate carbon neutrality does not exist (in French). By requiring evidence matching the depth of the claim, it restores measurement to a central role: a Bilan Carbone® assessment or a multi-criteria LCA (in French), depending on the depth of the claim.

The first task is to inventory your active claims and support each with the right evidence, without waiting for the French law. To establish precisely whether you are in scope, see who is affected by EmpCo.

Further resources

Frequently asked questions

1Are EmpCo and ECGT the same directive?

Yes. EmpCo and ECGT are two abbreviations of the same English title, Empowering Consumers for the Green Transition. The single legal reference is Directive (EU) 2024/825, adopted on 28 February 2024.

2Does the directive apply to small businesses?

Yes. EmpCo has no size or turnover threshold. For the environmental provisions, the criterion is communicating about the environment to consumers in the EU; the rules on durability and guarantee information cover every B2C seller. A micro-business is affected just as a large group is.

3Can I still call a product "carbon neutral"?

No, if neutrality relies on carbon offsetting outside the value chain: this is one of the practices the directive prohibits in all circumstances. Pending the transposing law, the French Environmental Code already regulates this strictly in advertising: the carbon footprint of the product or service over its life cycle, the reduction pathway and the offsetting arrangements must be published. You may communicate a measured reduction and show the carbon contribution separately.

4Does France's transposition delay protect me until the law is passed?

No. Existing French law on misleading commercial practices, the AGEC law and the regulation of carbon neutrality already penalise most of the practices covered, and judges interpret it in the light of the directive. The new blacklist prohibitions will apply in France with the transposing law.

5Where should I start?

Take an inventory of your active claims, including old pages still online. Remove anything no evidence can support, then create and retain an evidence sheet for each remaining claim.

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