Generic environmental statements
Words such as “green” or “environmentally friendly” can be prohibited without recognised excellent environmental performance relevant to the specific claim.
BuVNK · EmpCo · Reviewing environmental claims · Updated 14 October 2026
EmpCo 2026: Evidence, Documentation and Compliance
How businesses can substantiate sustainability messages, organise internal approvals and reduce the risk of misleading consumer-facing environmental claims.
Applicable since 27 Sep 2026B2C claims in focusEvidence and approvals
Important: EmpCo strengthens the EU rules on unfair B2C commercial practices. It does not impose a blanket third-party pre-certification duty or a prescribed evidence file for every environmental statement. Well-organised records are nonetheless prudent. Specific additional conditions apply, for example, to claims about future environmental performance and certain sustainability labels. The separate proposed Green Claims Directive should not be presented as already applicable EmpCo law. This is general information, not legal advice.
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Which claims should be reviewed?
Start with the overall impression a consumer receives from the message, not only claims displaying a green icon.
Quantified product claims
A statement such as “30% less material” needs a sound benchmark, traceable data and a clear description of the product and parameter compared.
Climate-related claims
Claims of neutral or reduced product greenhouse-gas impact based on offsetting are specifically prohibited; genuine reductions must be presented accurately.
Labels and future targets
Sustainability labels and future-performance promises call for additional checks of certification schemes, implementation plans, independent verification and transparency.
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What should an evidence file contain?
The following file structure is a practical recommendation, not a universal legally prescribed EmpCo dossier. The evidence needed depends on the claim, its scope and any sector-specific law.
Exact claim and creative assets
Record the wording, image, packaging, campaign, language, date and communication channel.
Scope and methodology
Clarify whether the claim concerns a product, packaging, single feature, lifecycle stage or the entire business; record boundaries and comparisons.
Underlying data
Retain measurements, supplier declarations, test reports, studies, methods, standard references, version and validity.
Approvals and changes
Keep accountable owners, risk review, sign-off, subsequent corrections, publication date and review triggers.
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Understanding the rules – EmpCo is not the Green Claims proposal
EmpCo prohibitions and misleading-practice rules already apply. Additional systematic pre-verification requirements under the separate Green Claims legislative proposal should not be represented as generally binding EmpCo obligations.
| “Our entire company is sustainable” | Assess whether the evidence only concerns certain products or activities. A claim wrongly covering the whole business can be prohibited. |
| “This product is climate neutral through offsetting” | Product climate-neutrality claims based on greenhouse-gas offsetting fall under a specific prohibition. A label does not override that ban. |
| “We will cut our footprint by 50% by 2030” | Future performance claims require clear, public, verifiable commitments, a realistic implementation plan and periodic independent third-party review. |
| A self-created “sustainably certified” seal | Check whether the label is based on an appropriate certification scheme or established by a public authority. Self-description alone is insufficient. |
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Eight steps to an EmpCo claims-approval process
01
Inventory the claims
Map websites, packaging, advertising, labels, point-of-sale displays and social content.
02
Assign accountable people
Include marketing, procurement, sustainability, legal/compliance and qualified experts as needed.
03
Assess consumer impression
Identify exact wording, imagery, footnotes, claim boundaries and consumer takeaway.
04
Screen clear prohibitions
Exclude offset-based product neutrality claims, unsupported generic claims, inappropriate labels and misleading whole-business statements.
05
Check supporting evidence
Review methods, source quality, recency, comparisons and accuracy.
06
Apply specific tests
For future commitments examine public plans and independent verification; for labels verify certification scheme requirements.
07
Record the sign-off
Keep the decision, responsible team, evidence version and all locations of the published claim.
08
Revisit and update
Set review triggers for product changes, data updates, new campaigns and legal developments.
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Frequently asked questions about EmpCo evidence
Does every green claim require a certificate?
No. EmpCo does not create blanket external pre-certification for all claims, but specific prohibitions and conditions may apply, including to labels and future targets.
Is an ISO certificate sufficient to call a product environmentally friendly?
Not necessarily. A certificate relates to a specified scope, assessment or management system. Its relevance to the advertised claim must be assessed.
Do environmental targets require independent review?
Advertising future environmental performance is subject to specific conditions including clear public commitments, realistic planning and regular independent review.
Can we advertise the entire business as green if one product line is certified?
Not if it falsely gives the impression that the evidence applies to the entire business rather than a specific part.
How often should evidence be refreshed?
EmpCo does not provide one universal refresh cycle for every claim. Use review triggers proportionate to claim risk, new data, product changes and relevant rules.
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Explore more BuVNK and EmpCo guidance
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Legal basis and official sources
Directive (EU) 2024/825 – official text ↗eur-lex.europa.euEuropean Commission – EmpCo and Q&A, September 2026 ↗commission.europa.euUnfair Commercial Practices Directive 2005/29/EC ↗eur-lex.europa.euGerman Unfair Competition Act (UWG) – official version ↗www.gesetze-im-internet.deEuropean Commission – Green Claims proposal (distinction) ↗environment.ec.europa.eu
BuVNK · EmpCo
Build a reliable green-claims review process
BuVNK provides orientation on verifiable sustainability communications and practical internal controls. Specific questions may require specialist legal or technical review.