Check green claims before others do. Starting September 27, 2026, new rules for environmental advertising will take effect. The EmpCo Directive strengthens protections against greenwashing. It applies not only to campaigns but also to website content, product pages, brochures, packaging, user manuals, and sales materials. Many claims still seem harmless today. “Climate-neutral.” “Sustainable.” “Environmentally friendly.” “Low-carbon.” Starting in 2026, they could become a risk if the supporting evidence, context, and clarity are lacking. husare identifies where your communication is vulnerable. And what needs to change so that your statements aren’t open to attack but still get your message across.
What is EmpCo?
EmpCo stands for “Empowering Consumers for the Green Transition.” EU Directive 2024/825 supplements the rules against unfair business practices and strengthens consumer rights regarding environmental and sustainability claims. It takes effect on September 27, 2026. At its core, it boils down to a simple question:
Can a company provide evidence to support its claims about the environmental impact of its product, brand, or service?
Among other things, the following will be particularly critical:
General environmental promises without verifiable results
Claims such as “climate-neutral,” when they rely primarily on offsets
Sustainability labels that are self-created or have not been sufficiently verified
Environmental claims about the entire product, even though they apply only to a part of it
Claims regarding durability, repairability, or environmental impact without reliable evidence
Communication that markets legal minimum standards as a special benefit
EmpCo is no substitute for branding. But it does set a limit on it: Any claims made must be understandable, specific, and verifiable.
What happens if you don’t comply?
The directive does not establish its own list of fines. Its rules are implemented in Germany through unfair competition law and can be enforced under competition law. The risk arises wherever communication becomes visible:
Cease-and-desist letters from competitors or trade associations
Claims for injunctive relief and preliminary injunctions
Costs for attorneys, courts, and last-minute corrections
Withdrawal or Replacement of Communication Materials Already Produced
Loss of trust among customers, business partners, and employees
The most costly consequence is rarely the warning letter itself. It’s the frenzy that follows: halting campaigns, rewriting copy, and disposing of printed materials—and having the sales team clarify what can still be said.
What we do for you:
We review your communications. We identify where your brand may be making excessive claims, where evidence may be lacking, and which statements need to be clarified before September 2026. The result: a prioritized basis for decision-making for marketing and sales. Our review does not replace legal advice or a lawyer’s approval.
1. EmpCo Online Check
For everything customers see online. The online check is designed for companies that want to review their most visible digital touchpoints quickly and systematically.
We check:
Company and Product Website
Selected landing pages and product detail pages
Shop and Service Texts
Newsletter Templates and Recent Mailings
Social media profiles and up to ten relevant posts or ad creatives
Digital sales materials, provided they are publicly available or in PDF format
We evaluate:
Environmental and Sustainability Terms
Climate Neutrality and Offset Statements
Seals, Certificates, and Labels
Statements regarding materials, origin, energy consumption, packaging, repairability, or lifespan
Statements whose frame of reference remains unclear
Areas where documentation should be reviewed internally or from a legal perspective
You will receive:
a communication map showing all relevant claims
A traffic light rating: critical, check, unremarkable
a prioritized list of actions based on visibility and risk
Specific text and structural guidelines for the most urgent passages
a 45-minute digital results workshop with the marketing team and the relevant departments
Suitable for: Companies that need to know quickly whether their public communications are ready—and where they should start.
2. EmpCo Comprehensive Checkup
When printed materials also need to be reviewed. The Comprehensive Review combines digital review with an inspection of physical communications. It is designed for companies whose environmental claims appear not only on their website, but also in sales materials, at the point of sale, or directly on the product.
We also check:
Product Brochures and Catalogs
Sales Brochures and Flyers
Packaging, inserts, and point-of-sale materials
User Manuals and Technical Documentation from the Customer’s Perspective
Trade Show and Sales Materials
Relevant ad creatives and campaign materials
You’ll also receive:
A complete inventory of claims across online and print media
a material matrix that includes the source, claim, risk level, and recommended action
Production prioritization: What can continue as usual, and what needs to be clarified before the next print run?
A Claim Guide for Marketing, Sales, and External Partners
a 60-minute digital resultsworkshop
a 30-minute virtual follow-up appointmentafter four to six weeks to address any outstanding actions
Suitable for: Companies with many touchpoints, long production cycles, and a sales team that relies on reliable data.
Optional modules:
On-site Claims Consultation
A standard approval process for new campaigns, product communications, or sales materials. husare reviews the communications before production and flags sections that require internal approval or legal clearance.
Claim and Text Revision
We develop more robust wording and revise prioritized pages or materials.
EmpCo Workshop on Marketing and Sales
Half a day. Real-world examples from your communications. Clear guidelines for new messaging.
Legal Validation
The new guidelines for environmental and sustainability disclosures are effective as of September 27, 2026. Our EmpCo-Check identifies communication risks and systematically prepares the necessary supporting documentation and approval decisions. It does not constitute legal advice and does not replace a review by a qualified legal advisor in legally critical individual cases.
Here’s how the check works:
Kickoff and Handoff of Materials: You provide us with the framework for the review and supply us with the content to be reviewed.
Claim Review: We identify statements, labels, and implicit environmental promises. Not every “green” image poses a legal risk. But some phrasing does.
Evaluation and Prioritization: We distinguish between obvious areas requiring action, unresolved issues regarding evidence, and statements that appear sufficiently clear from a communication standpoint.
Results Review: You know which issues need to be clarified first—and which materials shouldn’t be reprinted prematurely.
Implementation, if desired: We will revise the prioritized communication materials and establish guidelines for future claims.
Starting September 27, 2026, good intentions won’t count anymore. What will count are concrete statements. Let’s take a look at what your communication promises today—before others do.
Would you like to find out what the new transparency requirements mean for your company, your communications, or your content production?
Jule Giese is your contact at husare for questions regarding AI labeling and the responsible use of generative AI.
This article is intended as a general guide and is not a substitute for legal advice. Whether a disclosure requirement applies depends on the content, context, target audience, and method of publication. In borderline cases, it is advisable to seek legal review. Sources: Article 50 of the EU AI Act; European Commission Guidelines on Transparency Requirements for Providers and Operators of Certain AI Systems, available from the European Commission. The guidelines clarify the application of the provision but do not themselves constitute the text of the law.
