EmpCo Directive: What Online Shops Must Know About Green Claims Since 27 September 2026

“Sustainable”, “climate-neutral shipping”, “eco-friendly packaging”: claims like these appear in many online shops – in product texts, banners, badges in the footer or in carbon offset plugins. Since 27 September 2026, many of them are no longer allowed. The reason is the EU directive on empowering consumers for the green transition, EmpCo for short. Here is what has changed and how to make your shop compliant.

What is the EmpCo Directive?

Directive (EU) 2024/825 amends European consumer law to fight greenwashing and the early wear-out of products. EU countries had to transpose it into national law by 27 March 2026, and the new rules apply across the EU from 27 September 2026. In Germany, for example, this was done through an amendment to the Unfair Competition Act (UWG) and changes to consumer contract law. The rules apply to every advertising claim made to consumers – including older product texts that are still online.

What is now prohibited

European consumer law contains a “blacklist” of commercial practices that are always unfair, without a case-by-case assessment. New entries include:

• Generic environmental claims without proof: terms such as “eco-friendly”, “green”, “climate-friendly”, “ecological” or “sustainable” are only allowed if you can prove recognised excellent environmental performance, for example through the EU Ecolabel or a comparable officially recognised environmental label.
• Climate neutral through offsetting: claims such as “climate neutral”, “CO₂ neutral” or “climate positive” that are based on offsetting emissions with certificates are prohibited. This also applies to “climate-neutral shipping” through offset projects.
• Home-made sustainability labels: labels and badges are only allowed if they are based on a certification scheme with independent monitoring or have been established by public authorities. Self-designed “eco” badges are therefore off-limits.
• Part presented as the whole: an environmental claim about the entire product or business when it only concerns one aspect – for example “recyclable” for a product where only the packaging is recyclable.
• Legal requirements presented as an advantage: advertising legal obligations as a special feature of the offer, for example “free from …” for substances that are banned anyway.
• False claims about durability, repair and updates: for example promising a durability that is not proven, or concealing that a software update impairs a device’s functions.

Promises for the future

Claims such as “climate neutral by 2030” are not banned outright. However, they are only allowed with clear, verifiable commitments, a detailed implementation plan and regular checks by an independent expert. Without this basis, they count as misleading.

New notices on legal guarantee and commercial guarantees

Also since 27 September 2026, sellers must inform consumers about the legal guarantee with a harmonised EU notice (Implementing Regulation (EU) 2025/1960). In an online shop, a clearly visible general notice is sufficient. If the manufacturer offers a free durability guarantee for the whole product for more than two years, it must be shown with the harmonised EU label, in the shop right next to the product, for example beside the product image. If a product has an EU-wide repairability score, as smartphones and tablets do, this must be shown as well.

What is still allowed

Specific claims that can be proven remain allowed – and they are more convincing anyway:

• “Shipping box made from 100% recycled paper” instead of “eco-friendly packaging”
• “Made with green electricity”, if proven, instead of “produced in a climate-friendly way”
• “We support a reforestation project with €1 per order” instead of “climate-neutral shipping”
• Officially recognised labels such as the EU Ecolabel or the EU organic logo

Checklist for your shop

• Search product texts, category texts, home page, banners, newsletters and social media posts for terms such as “sustainable”, “eco”, “green”, “environmentally friendly”, “climate neutral” and “CO₂”
• Check labels and badges in your theme, footer and product pages – including those added by plugins
• Review carbon offset plugins for shipping and adjust their texts
• Don’t forget meta descriptions, product feeds such as Google Shopping and marketplace listings
• Keep proof on file for every environmental claim that remains
• Add the legal guarantee notice and, where applicable, the guarantee label based on the EU template

What happens in case of violations

Practices on the blacklist are unfair without further assessment. Depending on the country, competitors, consumer associations and authorities can take action, for example with cease-and-desist letters or injunctions, which quickly becomes expensive. Widespread cross-border violations can also lead to fines.

We help you implement the rules

We scan your WooCommerce shop for critical wording, adjust texts, labels and plugin output and add the new notices on the legal guarantee and commercial guarantees. Get in touch.

This article reflects the situation as of 29 October 2026 and is not legal advice.