Capture all claims
List every environmental and sustainability statement on websites, product pages, packaging, social media, advertising and sales documents.
EmpCo Checklist 2026 · For Businesses
EmpCo Checklist 2026: What businesses need to review
Use this practical checklist to systematically review environmental and sustainability communications: green claims, climate claims, sustainability labels, supporting evidence, internal approvals and documentation.
TransparencyEvidence-based claimsClear approval procedures
Practical business review
Eight-step EmpCo checklist
Use this table as an initial internal working document. For every claim, record the evidence, approval and current review status.
| Review step | Key question | Internal evidence |
|---|---|---|
| 1. Inventory claims | Which environmental or sustainability claims are currently in use? | Record claims on the website, packaging, advertising, social media and sales materials. |
| 2. Specify the claim | Is it clear exactly what the claim refers to? | Record the product, company, feature, time period and scope. |
| 3. Check permissibility and evidence | Is the claim legally permissible in this form, and is there reliable, current evidence to support it? | Assess permissibility first; then store studies, measurements, certificates, calculations and other supporting documents centrally. |
| 4. Review wording | Could the claim be misunderstood or interpreted more broadly than the evidence supports? | Compare the exact wording directly with the underlying evidence. |
| 5. Review labels | Are sustainability labels or comparable marks being used? | Check whether the label is based on a certification scheme or established by a public authority, and document the criteria and authorization for use. |
| 6. Climate claims and offsetting | Does a product claim a neutral, reduced or positive greenhouse-gas impact because of offsetting? | Do not publish offset-based product claims of this kind. Assess and communicate factual emissions information separately from climate investments or carbon-credit projects. |
| 7. Internal approval | Is responsibility assigned for reviewing and approving claims before publication? | Record the responsible person, approval date and evidence reviewed. |
| 8. Keep records current | Are claims and their supporting documents regularly reassessed? | Record review dates, the next scheduled review and any changes. |
Official legal sources: Directive (EU) 2024/825 · German UWG Annex · European Commission: Green Claims
Important: This checklist is an initial orientation tool. The assessment of a particular claim depends on its wording, context, evidence and applicable law. It is not a legal certification or an individual legal opinion.
Before publication
Eight detailed checkpoints
A structured process helps marketing, sustainability, legal and compliance teams review claims consistently.
Review generic green claims
Assess first whether a generic environmental claim is permissible. Where it conveys excellent environmental performance, recognised excellent environmental performance relevant to the claim must be demonstrated. Then check scope and substantiation.
Scrutinize climate claims
Product claims of a neutral, reduced or positive greenhouse-gas impact must not be based on offsetting. Calculation, certification or disclosure of offsets does not make such an offset-based product claim permissible.
Check sustainability labels
Determine whether a label is based on a certification scheme or established by a public authority. Scrutinize self-created or unverified labels.
Secure evidence and documentation
Keep relevant calculations, studies, test reports, certificates, material data and life-cycle assessments, where applicable.
Define internal approval procedures
Assign clear responsibilities across marketing, legal, compliance and sustainability functions as appropriate.
Specify the scope
State whether a claim applies to the entire product, a component, packaging, a process or the company as a whole.
Approve before publication
Publish only after a documented review. Record who approved the claim, the evidence relied on and the latest review date.
Green claims in practiceGeneric claim — high risk Illustrative direction Prohibited where based on offsetting Illustrative alternative
Clearer, more specific statements
“Our product is sustainable.”
“Sustainable” may cover environmental, social and other sustainability aspects. Where a generic environmental claim conveys excellent environmental performance, recognised excellent environmental performance relevant to the claim must be demonstrated. Evidence for one limited aspect does not automatically support an overall product claim.
“The packaging contains 85% recycled plastic.”
This example is not automatic legal clearance. Use a specific percentage only where it is factually correct, current and supported by appropriate evidence for the relevant packaging component.
“100% climate neutral.”
If the product claim of a neutral, reduced or positive greenhouse-gas impact is based on offsetting, the claim is prohibited. Certification or transparent offset documentation does not make that product claim permissible.
Communicate emissions and climate investments separately.
Product-related emissions data may be presented where the figures, method and boundaries are accurate and supportable. Information on separately financed climate or carbon-credit projects should be clearly separated and must not imply that the product itself is climate neutral or lower-emission because of offsetting.
Regulatory background
Key EmpCo dates
28 February 2024
Directive (EU) 2024/825 was adopted.
27 March 2026
Deadline for Member States to transpose the Directive into national law.
27 September 2026
Start of application of the new rules.
EmpCo amends EU consumer-protection rules. The requirements are particularly relevant to businesses making environmental or sustainability claims to consumers. The scope and national implementation must be assessed in each case.
About BuVNK
Making sustainability communication verifiable
BuVNK — the German Federal Association for Verified Sustainability Communication — brings together specialist information on EmpCo, Green Claims, PPWR and related requirements. Our focus is on clear guidance, credible evidence, transparent communication and professional dialogue.
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