EmpCo: Providing Credible Evidence for Environmental Claims
Obligation to provide roof, effective September 2026
Key Points at a Glance
- EmpCo stands for the EU directive “Empowering Consumers for the Green Transition”. Starting September 27, 2026, stricter EU-wide rules against greenwashing will apply to all industries.
- Vague terms such as “sustainable” will need to be backed up by precise, verifiable information in the future; self-created eco-labels are off-limits.
- The reference value, time period, and basis for comparison of a statement are crucial.
- In many companies, relevant data is scattered across technical systems, departments, and reports.
- EmpCo is a cross-functional initiative involving sustainability management, technology, communications, compliance, and legal affairs.
Note: This article is intended for general informational purposes only and does not constitute legal advice. Your own legal department or a specialized legal advisor should evaluate any specific statements.
Can Companies Back up Their Claims About Sustainability?
"Thanks to the measures we've taken, we've reduced energy consumption by 15 percent." That sounds concrete. But what does that 15 percent refer to? Which locations and time periods were considered, and what data support that statement?
Starting September 27, 2026, new requirements will apply to environmental and sustainability claims made to consumers. The EU directive “Empowering Consumers for the Green Transition,” or EmpCo for short, is intended to better protect consumers from misleading claims. Companies must more clearly define their environmental benefits and provide verifiable evidence of those benefits.
What the EmpCo Policy Requires
EmpCo is not an entirely new law. Its official name is Directive (EU) 2024/825. It is not an entirely new law, but rather a strengthening of existing EU consumer law—in particular, the Directive on Unfair Commercial Practices. In Germany, it was implemented through amendments to the Act Against Unfair Competition (UWG).
Among other things, the following are particularly relevant:
- General environmental statements—broad statements without sufficient detail—are becoming significantly more difficult to make.
- Climate neutrality claims that are based solely or partially on offsets.
- Self-created sustainability labels that are not part of a certification system established or recognized by a public authority.
- Statements about future environmental performance that require a solid basis.
The important thing to remember is that it’s still possible to use sustainability in your advertising. Sustainability is and remains a strong marketing selling point. However, how you talk about it is important. [dievisualisten.com]
Sound Statements Need a Solid Foundation
Terms like “sustainable,” “green,” or “environmentally friendly” are often used without much thought. However, without clarification, they can be misleading. What matters is what a statement actually refers to: the entire company, a product, individual locations, or a specific measure. The reference value, time period, and basis for comparison must also be clear.
The correct scope of a statement also plays a role here. A company improves one aspect of its product and, in its communication, extends this benefit to the entire product or even to the company itself. It is precisely this leap that is critical—because a statement about the entire product or the company’s entire business should not be based solely on a single aspect.
What Lies Behind an Environmental Claim
Claims regarding reduced consumption, lower emissions, or improved efficiency are often based on measurement, plant, and sustainability data. In many companies, this data is scattered across technical systems, departments, and separate reports. This makes it difficult to conduct consistent analyses and provide reliable evidence.
There is also a practical issue: In companies with many pages, products, and channels, it is often unclear exactly where environmental and sustainability claims are being used. A consistent data foundation helps ensure that such claims can be uniformly verified and substantiated in the first place.
Scattered Pieces of Information Come Together to Form a Coherent Overall Picture
A shared database consolidates energy, facility, and sustainability data from various sources. This allows information to be structured, tracked over time, validated, and analyzed. As a result, trends become apparent, and locations, facilities, or time periods can be compared using standardized metrics.
A platform such as green.screen, for example, follows this approach: green.screen helps you centrally collect, analyze, and transparently present energy and resource data. This allows you to lay the foundation for compliance, ESG reporting, and targeted efficiency measures. The specific implementation always depends on the particular use case and the available data sources.
15 Percent Less. But Compared to What?
This can transform a general statement into more precise information. Instead of merely claiming an improvement, one can specify the time frame, scope, key metric, and benchmark. This enhances transparency without prejudging any legal assessment.
This principle corresponds exactly to EmpCo's logic: The second column doesn't claim anything less—it simply explains more precisely what's really behind it.
Use the Same Foundation Within the Company
EmpCo is not merely a marketing task. Sustainability management, technical departments, sales, communications, compliance, and legal must work together. A shared database facilitates coordination and fosters a common understanding of the metrics used.
It’s also helpful to keep internal records supporting each claim. You don’t have to publish your supporting documents publicly on the website. However, they should be documented internally and available upon request—for example, if competitors, consumer advocacy groups, or regulatory agencies ask for them.
Credible Evidence to Support Environmental Claims
A data platform does not replace either the technical assessment or the legal approval of an environmental statement. However, it can consolidate relevant data, document trends, and provide evidence consistently.
After all, the crucial question remains: Can we prove what we claim?
Frequently Asked Questions and Answers About the EmpCo Policy
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When does the EmpCo policy take effect?
The new requirements will apply to environmental and sustainability claims made to consumers starting September 27, 2026.
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What exactly is EmpCo calling for?
Companies must define environmental benefits more clearly and provide verifiable evidence—including benchmarks, time frames, and a basis for comparison. Vague statements such as “sustainable” will require precise, verifiable information in the future; self-created eco-labels are off-limits.
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Is it even allowed to advertise using the term “sustainability” anymore?
Yes. The purpose of the guideline is not to stop you from talking about sustainability or promoting it. What matters is that your statements are precise and verifiable.
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Does a data platform replace legal approval?
No. It compiles relevant data and documents trends, but it does not replace either professional evaluation or legal approval.
Written by
Michael Kuhrs is the Head of the Measurement Systems Department and Product Business Owner for green.screen. With over 25 years of experience in the energy industry, his focus is on smart metering, metrology, and product management. Through green.screen, he helps companies meet regulatory energy requirements.