EmpCo: the EU green claims rules that apply from 27 September 2026

What EmpCo is

EmpCo amends two existing directives: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). Member States had to transpose it by 27 March 2026, and the national rules apply from 27 September 2026.

Because it works through consumer protection law, it applies to any business-to-consumer communication: product titles and descriptions, images and icons, brand or product names, ads, newsletters, social posts and packaging. It does not require claims to be approved in advance. Instead, authorities and competitors can challenge claims after they are published.

The new bans (Annex I)

Practices on the Annex I list are unfair in all circumstances. There is no case-by-case test. EmpCo adds:

EmpCo also adds bans on practices that shorten product life, such as falsely claiming a durability or presenting a product as repairable when it is not (points 23d to 23j).

Claims that need extra proof (Article 6)

Two new misleading actions are assessed case by case:

• Future environmental performance (Article 6(2)(d)): claims such as “carbon neutral by 2030” need clear, objective, publicly available and verifiable commitments in a detailed and realistic implementation plan with measurable, time-bound targets, verified regularly by an independent third-party expert whose findings are available to consumers.
• Irrelevant benefits (Article 6(2)(e)): advertising benefits that do not come from any feature of the product or business.

Key definitions

• Environmental claim: any non-mandatory message or representation, including text, pictures, graphics or symbols, that states or implies a positive or zero environmental impact, less damage than other products, or an improvement over time.
• Generic environmental claim: an environmental claim not on a sustainability label, where the specification of the claim is not given in clear and prominent terms on the same medium.
• Recognised excellent environmental performance: compliance with the EU Ecolabel, an officially recognised EN ISO 14024 type I ecolabel scheme, or top environmental performance under other applicable EU law.

The practical consequence: a vague word becomes acceptable only if you either back it with one of those recognised labels or replace it with a specific, provable statement shown right next to it.

Where the Member States stand

According to a review published by Mayer Brown in October 2026, several countries had not notified their national measures by the application date, including Spain, Sweden and Poland, and France's measures were still in progress. Others, such as Denmark and Slovakia, transposed early. Where national law is late, the directive's text is still the best guide to what courts and authorities will expect, and existing rules against misleading claims already apply.

What to do in your Shopify store

1. Search your whole storefront, not just product descriptions: titles, alt texts, SEO fields, metafields, collection descriptions, blog posts, banners and email templates.
2. Remove or replace generic words unless the product holds a recognised ecolabel for that claim.
3. Remove offset-based neutrality claims at product level.
4. Check every badge and icon: keep only labels from certification schemes or public authorities.
5. For each remaining claim, keep the evidence (certificate, test report, calculation) on file.
6. Repeat when you add products or copy supplier descriptions, which often contain these words.