EmpCo Is Coming. The Clock Is Not Resetting.
EmpCo applies from 27 September 2026. With national transposition still uneven, businesses should review environmental claims, sustainability labels and durability information now.
Directive (EU) 2024/825—the Empowering Consumers for the Green Transition Directive, or EmpCo—requires Member States to apply their implementing measures from 27 September 2026.
There is no additional transition period. From that date, the amended Unfair Commercial Practices Directive and Consumer Rights Directive are intended to apply through national law.
What changes for businesses marketing products to EU consumers?
Generic environmental claims →
Claims such as “green” or “eco-friendly” will be prohibited unless the trader can demonstrate recognised excellent environmental performance relevant to the claim.
Offset-based climate claims →
Claims that a product has a neutral, reduced or positive greenhouse-gas impact cannot be based on carbon offsetting.
Sustainability labels →
Sustainability labels must be based on an approved certification scheme or established by a public authority. Self-created logos will no longer provide a credible shortcut.
Pre-contractual product information →
New requirements will cover matters including durability, reparability and software-update policies. The Commission has already adopted the harmonised notice and label designs.
Premature obsolescence →
Commercial practices that encourage premature obsolescence are explicitly targeted.
The point most compliance timelines miss
The transposition deadline—27 March 2026—has already passed. On 28 May, the Commission opened infringement procedures against 20 Member States for failing to communicate complete transposition.
That does not postpone the September timetable.
It does mean that the route to implementation is uneven across the Union.
The practical conclusion
For regulatory affairs, legal and marketing teams, the practical conclusion is straightforward: do not wait for every national measure to be finalised before preparing.
At the same time, national implementation still matters. Businesses must understand both the common direction established by EmpCo and the legislation through which each Member State gives it effect.
Claims substantiation, sustainability labels and product information should be reviewed now.
The organisations best placed on 27 September will not be those still watching the transposition process. They will be those that have already examined the evidence behind their claims, removed vulnerable language and adapted their consumer-facing information.
What is your organisation’s biggest open question on EmpCo: claims substantiation, sustainability labels, or durability and reparability disclosures?
For more information, contact Nexum EU Strategies.
Discuss the implications for your file.
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