Green Claims 2026 · Environmental advertising · Sustainability communicationEmpCo Directive
Focus: Green Claims, environmental and sustainability statements, sustainability labels, climate claims and protection against misleading commercial practices.
Green Claims 2026 · Environmental advertising · Sustainability communication
Green Claims 2026: What businesses need to know
Green Claims are under closer scrutiny in 2026. Businesses should phrase environmental and sustainability statements clearly, define precisely what each claim refers to and keep reliable supporting evidence. Our EmpCo-Checkliste 2026 helps you review your claims. Broad environmental claims, climate claims and insufficiently substantiated sustainability labels are especially sensitive.
Neutrality
Scientific rigour
Transparency
EmpCo DirectiveApplicable from 27 September 2026
PPWRFrom 12 August 2026
Green Claims DirectiveLegislative procedure
GuidanceMonitoring regulatory developments
Expert informationWhite papers, guides and practical recommendations
DialogueBusiness, science, policymakers and authorities
TrustTransparent and verifiable sustainability communication
Green Claims 2026: Key requirements for businesses
In 2026, environmental claims need to be clearer, more specific and better supported. Businesses should check exactly what an environmental statement refers to, which evidence supports it and whether consumers can understand it. Claims must not create a misleading overall impression.
Green Claims Directive
Focus: substantiation of voluntary environmental claims.
PPWR – Regulation (EU) 2025/40
Recyclability, recycled content, reuse, packaging minimisation, labelling and the circular economy.
ESPR
Repairability, durability, recyclability, materials, resource efficiency and digital product information.
Digital Product Passport
Standardised digital information about products.
CSRD
Many companies will have to report in detail on the environment, climate, social responsibility and corporate governance.
ESRS
The ESRS define the detailed content of sustainability reports under the CSRD.
EU-Taxonomie
A common classification system for sustainable economic activities.
EU Batteries Regulation
Carbon footprint, recycling rates, traceability and due diligence obligations.
EU regulations at a glance
Expert information on the most important regulatory frameworks.
The Association helps businesses keep track of developments and understand regulatory requirements.
The new EU directive against greenwashingEmpCo Directive (EU) 2024/825
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EmpCo Directive (EU) 2024/825
The Empowering Consumers for the Green Transition Directive is a major EU initiative on sustainability communication. It aims to better protect consumers from misleading environmental statements and strengthen informed purchasing decisions.
28 February 2024Directive adopted
26 March 2024Directive entered into force
By 27 March 2026Transposition into national law
From 27 September 2026New rules apply
Which businesses are affected?
- Manufacturers and brand owners
- Importers, retailers and online shops
- Packaging manufacturers
- Food, cosmetics, textiles, furniture and electronics companies
- Service providers
Which statements are particularly sensitive?
- sustainable, environmentally friendly, ecological and green
- climate-friendly, climate-neutral and carbon-neutral
- emission-free and resource-efficient
- biodegradable, recyclable and plastic-free
- graphic elements and self-created environmental labels
What requirements apply?
- factually accurate
- supported by scientifically verifiable evidence
- not misleading
- regularly reviewed and up to date
- clear and understandable for consumers
What can happen if rules are breached?
- Fines and formal warnings
- Injunctions and unfair competition proceedings
- Sales restrictions and withdrawal of advertising materials
- Court proceedings
- Reputational damage and loss of trust
BuVNK recommendations: Review existing sustainability claims, document supporting evidence, establish claim management, train marketing and sales teams, and introduce transparent review and approval procedures.
Additional requirements for substantiating Green ClaimsGreen Claims Directive
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Green Claims Directive
EmpCo already applies. The separate Green Claims Directive remains an EU legislative proposal. As of 8 October 2026, the European Commission lists the proposal as pending. It would introduce additional requirements for substantiation, communication and verification of explicit environmental claims, but those proposed requirements must not be presented as law already in force.
What does the proposal currently envisage?
- scientifically substantiated
- documented transparently
- objectively verifiable
- communicated transparently
- up to date
What evidence does the proposal identify as relevant?
- Scientific studies and laboratory tests
- Material analyses and carbon footprint calculations
- Life-cycle assessments
- Supplier declarations and certifications
- Audit reports, records and traceability evidence
Expert note: The EmpCo Directive has already been adopted and has fixed implementation deadlines. The Green Claims Directive is still a legislative proposal and may be amended.
The new European Packaging RegulationPackaging and Packaging Waste Regulation (PPWR)
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Packaging and Packaging Waste Regulation (PPWR)
The PPWR is one of the EU's most extensive packaging-law reforms in decades. It aims to make packaging more sustainable, substantially reduce packaging waste and promote a circular economy.
11 February 2025Entry into force
From 12 August 2026Most provisions become applicable
2027 to 2030Further obligations
By 2040Additional targets
Key requirements
- Recyclability
- Packaging minimisation
- Minimum recycled-content levels
- Reuse
- Labelling
- Documentation obligations
BuVNK recommendations
- Analyse all packaging used
- Assess recyclability
- Determine recycled-content shares
- Build robust documentation
- Review the supply chain
- Introduce digital evidence systems
Design for Recycling: Businesses should consider materials, material combinations, adhesives, labels, inks and subsequent sorting as early as product development.
Transparency across the value chainDigital Product Passport (DPP)
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Digital Product Passport (DPP)
The Digital Product Passport is a key EU initiative under the European Green Deal. Its purpose is to make product information digitally available in a standardised, transparent way along the value chain.
What information can a Digital Product Passport contain?
- Manufacturer details and product identification
- Material composition and raw materials used
- Recycled content and recyclability
- Repair information, spare parts and maintenance instructions
- Carbon footprint, certifications and supporting evidence
- Disposal instructions and QR code
BuVNK recommendations
- Record product data systematically
- Document material information
- Manage evidence digitally
- Make supply chains transparent
- Monitor regulatory developments
- Integrate digital information systems early
Connection to the PPWR: A Digital Product Passport can provide material information, recycled-content data, recycling information and evidence of compliance.
EmpCo 2026 · Green Claims · Sustainability labels
Which Green Claims are particularly sensitive in 2026?
Broad environmental terms such as “sustainable”, “environmentally friendly”, “green” and “ecological”, as well as climate claims such as “climate-neutral” or “carbon-neutral”, require particular care. Businesses should assess exactly what the claim means and how it is supported.
“Our product is environmentally friendly.”
Generic environmental claims such as “environmentally friendly”, “green” or “ecological” must not be used unless recognised excellent environmental performance relevant to the claim can be demonstrated. The full presentation must not mislead consumers.
“The packaging contains 85% recycled plastic. The proportion has been independently verified.”
This identifies the component, the specific property and the fact that verification has taken place.
“100% climate-neutral.”
Product-related claims such as “climate-neutral” or “carbon-neutral” are prohibited where they are based on offsetting greenhouse gas emissions outside the product's value chain. Businesses should distinguish actual emission reductions from offsetting activities.
“Product-related greenhouse gas emissions have been calculated using recognised standards.”
Communicate actual, substantiated emissions data and specific reduction measures. Investments in climate protection or offsetting projects can be described separately, provided they do not create a misleading impression about the product's climate impact.
Is the claim legally permissible in this form?
Is it accurate and appropriately substantiated?
Is the statement complete?
Could consumers be misled?
Is the data up to date?
Is the statement unambiguous?
Is the supporting evidence documented?
Would an independent third party reach the same conclusion?
Official sources
Legal basis and legislative status
The guidance on generic environmental claims, sustainability labels and offset-based climate claims is based on Directive (EU) 2024/825 (EmpCo) and the applicable national implementation. The separate Green Claims Directive remains a legislative proposal; the European Commission lists it as “Pending” as of 8 October 2026.
Directive (EU) 2024/825 – EUR-Lex
Green Claims – proposal COM(2023) 166 – EUR-Lex · European Commission – current status
Updated: 8 October 2026
Green Claims 2026 · Frequently asked questions
Green Claims 2026: Answers to key business questions
European sustainability regulation raises many questions for businesses. The Association provides clear, practical answers to frequently asked questions.
Does every business have to comply with the new EU rules?
The rules concern consumer-facing commercial practices rather than a simple company-size threshold. Relevance depends on the specific claim, the marketing context and the applicable national implementation.
What is a sustainability claim?
A sustainability claim is a statement or presentation that gives consumers the impression that a product, packaging, service or company has particular environmental or sustainability characteristics.
Can I still use the word “sustainable”?
Only with great care. “Sustainable” may cover environmental, social and other sustainability aspects. Where the message amounts to a generic environmental claim conveying excellent environmental performance, recognised excellent environmental performance relevant to that claim must be demonstrated. Evidence for one limited attribute does not automatically support an overall sustainability claim.
Are certificates now mandatory?
Not for every individual environmental claim. Sustainability labels are subject to specific rules: in principle, they must be based on a certification scheme or established by a public authority. In every case, the underlying claim must also be legally permissible and factually supportable.
Does EmpCo only apply to large companies?
No. EmpCo concerns consumer-facing commercial practices and is not based simply on company size. The specific claim, context and scope of the applicable rule are decisive.
What is the difference between EmpCo and the Green Claims Directive?
EmpCo is adopted and its consumer-protection rules apply. The separate Green Claims Directive remains an EU legislative proposal. As of 8 October 2026, the European Commission lists the proposal as pending, so its proposed substantiation and verification requirements may still change.
What role does the PPWR play?
The PPWR primarily governs packaging, including recyclability, recycled content, reuse, packaging minimisation, labelling and documentation. It also affects what businesses can credibly communicate about packaging sustainability.
How can my business prepare?
Businesses should systematically review existing environmental and sustainability claims, document supporting evidence, establish clear internal approval procedures and improve cooperation between marketing, legal and compliance teams.
Green Claims · EmpCo 2026
Green Claims from 27 September 2026: What businesses need to know
The EmpCo requirements increase the standards for environmental and sustainability statements addressed to consumers from 27 September 2026. Businesses should therefore review Green Claims for clarity, substantiation and the overall impression before publication.
Generic environmental statements, climate-related advertising, sustainability labels and statements about future environmental performance are particularly relevant. What matters is the specific message conveyed to consumers and the evidence behind it.
Learn more about the new requirements on our EmpCo Directive 2026 page. For a practical review, see our EmpCo Checklist 2026 .
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