Week One of EmpCo: When a Whiteboard Idea Comes to Life

Since September 27, 2026, the new rules of the EU Empowering Consumers for the Green Transition Directive, or EmpCo (Directive (EU) 2024/825), have applied. We are now in the first week of implementation. Time for a progress report, a look at the bigger picture, and an honest glimpse of what has been happening behind the scenes.

What EmpCo changes

The directive aims to better protect consumers from greenwashing. In practice, this mainly means:

• Generic environmental claims such as “eco-friendly” or “climate-friendly” are only permitted if recognized excellent environmental performance can be demonstrated.
• Climate neutrality claims for products that rely solely on offsetting are no longer allowed.
• Sustainability labels must be based on a certification scheme or established by public authorities. Self-awarded labels are no longer sufficient.
• Claims about future environmental performance require a detailed, verifiable implementation plan that is monitored by independent experts.

For companies, this means that communication, product claims and labels need to be put to the test. That is exactly where we have supported many customers over the past months.

What lies behind us

The implementation did not begin on September 27. Over the past weeks and months, we have:

• built a complete certification system that meets the new requirements,
• carried out system audits and consistently adjusted our solutions to the new rules,
• read, evaluated and applied every piece of guidance from the European Commission and translated it into practice,
• held countless customer meetings.

Take aways from customer conversations

Many questions came up again and again, and every one of them was legitimate: What can I still say? What applies to existing stock? How should I handle existing labels? Where is the line between a product claim and a company claim?

The recurring questions in particular showed us where uncertainty is greatest. They sharpened our solutions and made our explanations clearer. Every conversation made the system a little better.

A system takes shape

A certification system that was first designed on digital whiteboards and in many meetings is now being used in everyday practice. That is the most exciting moment: what looked coherent on paper has to prove itself in real cases.

We are being honest: this is not the final version. Open questions of interpretation, new practical cases and further guidance from the authorities will continue to accompany us. That is exactly why we see these first weeks as a learning phase in which we listen, adjust and improve.

What comes next

We will keep at it and keep sharing our experience.