Empowering Consumers Directive (EU 2024/825)

What is it?

The Empowering Consumers Directive, Directive (EU) 2024/825 of 28 February 2024, extends EU unfair competition law with specific prohibitions on environmental claims in market communication. It amends the Unfair Commercial Practices Directive and the Consumer Rights Directive and creates a harmonised EU-wide framework for substantiating environmental claims. The directive has been in force at EU level since March 2024. Application begins, after transposition into national law, on 27 September 2026.

Generic environmental claims without evidence are prohibited. Terms such as “climate neutral”, “environmentally friendly”, “eco” or “green” may no longer be used as blanket statements. Such claims have to rest on scientifically substantiated, clear, specific and verifiable data, or come from officially recognised environmental label schemes, whether EU or national. Climate neutrality claims resting solely on offsetting are not admissible. Forward-looking claims such as “climate neutral by 2030” are only allowed where a credible, documented implementation plan sits behind them.

EmpCo is therefore the central active EU lever against greenwashing. The Green Claims Directive originally announced was shelved by the European Commission on 20 June 2025. It was intended as a complement and would have added detailed substantiation and verification obligations. With it gone, EmpCo remains the only binding EU framework intended to discipline environmental claims.

Who is affected?

The directive addresses every manufacturer, importer and distributor that makes environmental claims in product communication. Primarily in B2C communication, but in practice with effects on B2B supply chains too. Specifically affected are the following.

• Websites, data sheets, product brochures, advertising, packaging and sales material
• Any statement about greenhouse gas reduction, “climate neutral”, “low carbon”, “sustainable” or “environmentally friendly”
• Sustainability seals and voluntary labels, where they carry an environmental claim

For manufacturers of construction products EmpCo works mainly indirectly. Architects, client advisers and housing companies communicate towards end customers on the basis of manufacturer data. Putting blanket claims of sustainability or climate neutrality about your product into the market exposes not only you but also the market partners who repeat those claims. Manufacturers advertising low-carbon concrete, climate-friendly insulation or similar attributes are addressed directly. The requirements apply to every individual claim, and blanket wording without substantiation is inadmissible once application begins.

Which deadline applies?

The dates at a glance.

• March 2024: the Empowering Consumers Directive enters into force at EU level.
• 20 June 2025: the Green Claims Directive is shelved by the European Commission, leaving EmpCo as the main active lever at EU level.
• 27 March 2026: deadline for transposition into national law.
• 27 September 2026: the national transpositions begin to apply. From that date the new rules are binding for all companies.

27 September 2026 is the hard date: from then the national transpositions of the Empowering Consumers Directive apply. The directive provides no transitional period for existing material such as websites, packaging or printed advertising. Anyone still carrying generic claims in the market on the day of application is operating at risk from that day.

What has to be done?

The tasks sort into three layers.

• Take stock: inventory every existing environmental claim across your website, data sheets, product brochures, advertising, sales material and packaging. For each claim, establish which impact category it addresses, which reference unit it means and which period it covers.
• Substantiate: document the data basis for each claim, ideally based on an EPD, an LCA or a PCF. EPDs and LCAs supply exactly the substance EmpCo demands: scientifically substantiated, clear, specific, verifiable and comparable. Where a dependable data basis is missing, the claim has to be adjusted or removed.
• Clear out high-risk claims: climate neutrality claims resting solely on offsetting are no longer admissible once application begins. Review those claims immediately and remove them where necessary, along with blanket terms such as “sustainable” or “environmentally friendly” without a clear reference unit.
• Secure forward-looking claims: anyone communicating “climate neutral by 2030” or comparable commitments needs a credible, documented implementation plan with milestones, reduction pathways and verifiable interim targets.
• Clarify market partner interfaces: data and claims going to architects, planners, sales partners or consumer communication have to rest on the same method and depth as your own material. Responsibility for substantiation does not travel down the value chain with the claim.
• Establish a sign-off process: train marketing and sales teams and extend approval workflows so future claims are tied to verified data. Every new environmental claim passes through methodological substantiation before publication.

What happens if you do not?

The Empowering Consumers Directive works through national unfair competition law. Breaches are sanctioned in two ways.

• Civil law: warning letters from competitors and consumer associations, injunction proceedings with legal costs, and damages claims. Consumer organisations and close competitors are active litigants in the greenwashing field, and EmpCo deliberately lowers the threshold for complaints.
• Administrative: fines from national consumer protection authorities. The level follows the national transposition.

On top of that comes reputational risk. A successful greenwashing claim travels quickly through the trade press and damages sustainability standing built up over years. With the Green Claims Directive gone, the whole of the EU’s disciplinary pressure concentrates on EmpCo. Working without methodological rigour here means operating in an increasingly sharp sanctions environment. In practice EmpCo shifts the market standard: making environmental claims without a dependable LCA, EPD or PCF data basis means operating at risk, while working methodically buys both defensibility and differentiation.