What is EmpCo – and can your company still call itself climate-smart?

In Sweden, the legislation is delayed and is proposed to take effect on 1 January 2027, but nothing has been decided yet [3][5]. That’s no reason to wait, though, since other EU countries have already written the rules into their own laws. Here’s what EmpCo is, what it means for your company and where the pitfalls are.

What is EmpCo?

EmpCo stands for Empowering Consumers for the Green Transition. It’s an EU directive (2024/825) that targets greenwashing, meaning environmental claims that are misleading, exaggerated or impossible to verify [1].

The directive isn’t an entirely new law. It amends two existing EU directives: the one on unfair commercial practices and the one on consumer rights [1]. In Sweden, the changes will be added to the Marketing Practices Act, the same law that already governs how companies can market themselves [3].

Why are new rules needed?

When the European Commission reviewed environmental claims in 2020, 53 percent were found to be vague, misleading or unfounded. A full 40 percent had no supporting evidence at all [2].

The Marketing Practices Act has long required environmental claims to be substantiated, but this has been assessed case by case. EmpCo bans certain claims outright by adding them to the so-called blacklist [1].

When do the rules apply in Sweden?

The directive was adopted in February 2024. Member states were supposed to transpose it by 27 March 2026, and the rules apply from 27 September 2026 [1]. The Commission has said there will be no additional transition period [6].

Sweden, however, hasn’t finished the job. The government inquiry proposes that the Swedish amendments take effect on 1 January 2027 [3][11], and at the end of September 2026 there was still no law in place [5]. Sweden is one of the 20 countries that received a formal notice from the Commission in May 2026 for missing the deadline [5][7].

That said, the basic rule that environmental claims must be substantiated already applies today under the Marketing Practices Act. What EmpCo adds is that certain claims become banned outright, with no case-by-case assessment [1]. In Denmark, for example, the new bans have applied since 27 September [12], and if you sell to consumers in other EU countries, their rules may already apply to you.

What does EmpCo mean for companies?

The core idea is simple: an environmental claim must be specific, true and possible to prove. And it’s not just about text. Images, symbols, product names and brand names count too [1]. The rules cover what you choose to communicate voluntarily. Information you’re legally required to report isn’t covered. But if you take that same information from your sustainability report and use it on a product page, in an ad, in a brochure or on your sustainability page, the rules apply there too.

Generic environmental claims are banned

Broad terms like “environmentally friendly”, “green”, “eco” and “climate friendly” can only be used if you can demonstrate recognised excellent environmental performance [1]. In practice, that means the EU Ecolabel or an officially recognised ecolabel, which includes the Nordic Swan Ecolabel, according to the Swedish inquiry [4]. Most companies don’t have that, and need to be specific instead: “the packaging is made from 80 percent recycled plastic”.

The term “sustainable” is even trickier. The word also covers social aspects, so an ecolabel alone isn’t enough to back it up [1].

Want concrete numbers instead of nice words? With GoClimate, your company’s emissions are calculated automatically from invoices and receipts.

Specific claims still need proof

Being specific is good, but you still need to be able to show that what you say is true. If you say the packaging is made from 80 percent recycled plastic, you need evidence for it, such as a certificate from your supplier.

Sustainability labels must be certified

Your own seals and badges are only OK if they’re based on a certification scheme with independent verification, or have been established by a public authority [1]. This applies to both environmental and social labels. So a home-made “Green choice” icon in your online store won’t cut it.

Offsetting doesn’t make a product climate neutral

You can’t claim that a product has a neutral, reduced or positive climate impact thanks to carbon credits [1]. Back in 2023, the Swedish Patent and Market Court ruled against Arla for its “net zero climate footprint” label [14]. The difference now is that these claims are always banned. You can still say that you fund climate projects, but as a contribution. Not as if the product’s emissions have disappeared.

Future commitments need a plan

Goals like “net zero by 2040” or “fully circular by 2030” can only be communicated if there’s a detailed and realistic plan with measurable, time-bound interim targets. An independent expert must review the plan regularly, and the results must be available to consumers [1].

A part can’t be presented as the whole

If only the packaging has been improved, you can’t give the impression that the whole product, or the whole company, has been [1].

Want to say something specific about an individual product? With GoClimate’s product carbon footprint (PCF) calculations, you get the product’s climate footprint in black and white.

Legal requirements aren’t a competitive edge

You can’t highlight something the law already requires of all products in the same category as if it were your thing [1]. “Phosphate-free detergent” doesn’t impress anyone when phosphates in consumer detergents are already heavily restricted across the EU [8].

Social sustainability, durability and repairs count too

EmpCo isn’t only about the environment. If you say something about working conditions, fair trade or animal welfare, the same rules apply: it has to be true and you have to be able to prove it. If you use a sustainability label for social issues, it must be based on a proper certification scheme or come from a public authority, just like an ecolabel. You also can’t give a misleading picture of how long a product lasts or whether it can be repaired. And the rules on how you inform customers about warranties and spare parts are getting stricter [1].

Does EmpCo apply to B2B?

The directive covers marketing to consumers [1], but that doesn’t mean B2B companies are automatically off the hook. Your website and LinkedIn posts can be read by anyone, not just other businesses.

EmpCo also adds new items to the so-called blacklist, the Swedish list of marketing practices that are always banned. These include vague claims like “environmentally friendly” without evidence, and claims that a product is climate neutral thanks to offsetting.

In Sweden, the blacklist currently also applies to marketing aimed at businesses. The inquiry proposes that it should only apply to consumers going forward, but nothing has been decided yet [3][4]. And even if the proposal goes through, misleading environmental claims are never allowed, not even towards businesses.

So even if you sell to businesses, it’s wise to assume the rules apply to you.

Who enforces the rules?

The Swedish Consumer Agency is the supervisory authority, and the Consumer Ombudsman can take companies to court or, in less serious cases, issue a ban directly [4]. Companies that break the rules can be ordered to pay a market disruption fee of up to 4 percent of annual turnover [4][10]. Competitors can also bring a case before the Patent and Market Court.

What’s different now is the burden of proof. If a claim is on the blacklist, it’s always considered unfair, and no one needs to show that consumers were actually misled [1].

Common pitfalls

Images and symbols count too

A green leaf, a globe or a bee on the packaging can be an environmental claim in itself [1]. It’s the overall impression that matters, not just the text.

Old material is still out there

The rules apply in full from 27 September 2026, and there’s no transition period for material that’s already out there [6]. However, consumer authorities across the EU have agreed that they can be a bit more lenient with products and packaging made before the rules took effect. If a company has a large stock of old packaging, for example, the authority may ask them to fix it rather than issuing penalties right away [7].

But this mainly applies to physical products. Online content is easy to change, so authorities are less forgiving there. You’re expected to do what’s reasonable and be able to show what you’ve done [7]. That blog post from 2021, the product sheet in your archive and old social media posts are exactly the kind of things you should review now.

Brand and product names

A product name like “EcoLine” or “GreenFlex” can count as a generic environmental claim [1].

Figures from the sustainability report

The sustainability report itself isn’t marketing. But if you put one of its figures on your homepage or in a campaign without context, it becomes a claim. Then it has to be accurate, clearly scoped and possible to verify.

With GoClimate’s VSME support, you build your sustainability report on real data.

Waiting for Green Claims

The Green Claims Directive was meant to complement EmpCo with more detailed rules on when an environmental claim can actually be used. It covered what requirements a claim must meet, how it should be substantiated, and that it should be reviewed by an independent party before use. But the proposal is on hold. In June 2025, the Commission announced its intention to withdraw it, and negotiations were halted [9]. It hasn’t formally been withdrawn, but there’s no timeline for when, or if, it will return [13]. EmpCo is what applies.

How to get started

Start by taking stock of all your environmental claims: website, packaging, sales material, social media and ads. For each claim, ask yourself: is it specific, does it apply to the whole product, and do we have the evidence documented?

Then swap vague words for concrete facts. A specific claim needs specific numbers, and they’re much easier to stand behind if they come from up-to-date sustainability reporting rather than an estimate in a spreadsheet.

With GoClimate’s sustainability report, your numbers fall into place automatically, pulled from invoices and receipts and structured according to the EU’s voluntary standard.

Make it a routine. Numbers change, suppliers switch and targets move. Appoint someone to own the issue, ideally together with marketing, sustainability and legal, and review your claims at least once a year.

New claims

Before you publish something new, it’s worth pausing for a moment. These questions help you find the weak spots before someone else does:

• What exactly are we saying?
• How would an ordinary consumer interpret it?
• Does our evidence cover the whole message?
• Is the claim about one feature, the whole product or the whole company?
• If it’s a claim about the future, is there a credible plan with interim targets behind it?

If you can’t answer all of these questions, it’s usually the evidence that’s missing. A strong claim starts with numbers you can trust.

GoClimate calculates your company’s carbon footprint automatically from invoices and receipts, so you can communicate with facts instead of fluff. Get started with GoClimate or book a demo.