EmpCo Directive: Checking environmental claims with Claude

TL;DR

• The EmpCo Directive (EU) 2024/825 has applied in Germany since September 27, 2026, through the German Act Against Unfair Competition (UWG). There is no general transition period for existing content.
• Generic environmental claims are now only allowed with a specific explanation on the same medium or a recognized eco-label.
• Product claims such as "climate-neutral" are always prohibited if they are based on offsetting greenhouse gas emissions.
• Our Claude skill checks copy against the EmpCo rules.

Since September 27, 2026, a product page that just says "environmentally friendly" with nothing to back it up can trigger a cease-and-desist letter. After the AI labeling requirement and the withdrawal button, the EmpCo Directive is the next EU rule that directly affects your online marketing. That's why we built a Claude skill that checks your copy for environmental claims.

What is the EmpCo Directive?

EmpCo (Empowering Consumers for the Green Transition) is the short name for EU Directive 2024/825. It takes aim at greenwashing, which includes misleading environmental claims, false statements about social characteristics, and untrustworthy sustainability labels. It also targets early obsolescence.

In Germany, the EmpCo Directive is implemented through the Act Against Unfair Competition (UWG) and has applied since September 27, 2026. There is no general transition period. Website copy you published years ago is covered too, as long as you keep using it.

What counts as an environmental claim under the EmpCo Directive?

Under the EmpCo Directive, an environmental claim is any voluntary advertising statement about the environmental impact of a product, a product category, a brand, or a company. The directive distinguishes four types of environmental claims:

• Positive impact. "Conserves resources"
• No impact. "Does not harm the environment"
• Less impact than other products. "More environmentally friendly than conventional products"
• Improved impact. "30% less plastic than before"

Even a statement that only implies one of these effects counts as an environmental claim.

Which environmental claims are prohibited under the EmpCo Directive?

The following practices are banned under the EmpCo rules. There's no case-by-case assessment.

Recognized excellent environmental performance exists when a product carries the EU Ecolabel or an officially recognized EN ISO 14024 Type I eco-label, or meets top-level requirements under other EU legislation, for example energy efficiency class A.

Claims that require a case-by-case assessment

Future performance claims such as "climate-neutral by 2030" are only permitted if all four requirements are met:

• clear, objective, publicly available, and verifiable commitments
• a detailed, realistic implementation plan with measurable, time-bound targets
• regular verification by independent external experts
• verification results that are accessible to consumers

Irrelevant benefits can be misleading. The directive gives the example of paper advertised as plastic-free.

Social characteristics, durability, repairability, and recyclability now count as main characteristics of a product. Terms like "sustainable," "conscious," or "responsible" therefore cover more than the environment, so you can't base them on environmental performance alone.

How can you still advertise environmental benefits under the EmpCo Directive?

• Specific, not generic. The claim is clearly explained on the same medium. Example from the directive: "100% of the energy used to produce this packaging comes from renewable sources."
• The right eco-label. "Energy-efficient" can be backed by energy efficiency class A. "Biodegradable" can be backed by the EU Ecolabel only if its criteria require biodegradability.
• The right scope. Claims about the entire company are allowed if they're accurate, verifiable, and not exaggerated.
• Keep climate action separate. You can promote investments in environmental projects, as long as you don't turn them into a product claim such as "climate-neutral."

Do the EmpCo rules also apply to social media, paid ads, and metadata?

Yes, the EmpCo rules apply on every channel. They cover social media posts, paid ads like Google Ads, and metadata, as well as the newsletters you use to promote your business. You have to explain any generic environmental claim on the same medium. Whether the landing page an ad links to is enough hasn't been settled in court yet.

Germany's Federal Court of Justice (BGH) ruled in 2024 that an ambiguous environmental term generally has to be explained in the advertisement itself. Explanations that consumers have to track down on their own aren't enough (judgment of June 27, 2024, I ZR 98/23). Ad copy, social media posts, and metadata leave very little room for that. It's safer to avoid generic environmental terms like "environmentally friendly" or "sustainable" there altogether.

EmpCo check with Claude: ganztags. workflow

We built a Claude skill that evaluates environmental claims against the EmpCo Directive. We use the skill to keep our clients up to date on the new rules and to find passages on their websites that need revising.

The EmpCo skill either checks existing copy or writes new copy that complies with EmpCo from the start.

1. Clarify the evidence. Claude asks which labels, certificates, or test reports you have.
2. Identify environmental claims. The AI model flags and evaluates every statement that touches on the environment, climate, materials, or labels.
3. Phrase it specifically. If there's evidence, the text mentions the specific property and the proof. If there isn't, it sticks to verifiable facts like material or dimensions, always in the respective brand's tone of voice.
4. Flag open points. Claude closes with a list of what still needs to be confirmed before publishing.

Important: The EmpCo check doesn't replace legal advice. Every company should have its specific wording, evidence, and labels reviewed by its own legal counsel before publishing.

Checklist: Are your environmental claims EmpCo-compliant?

Use these six points as a roadmap, so nothing important slips through when you implement the EmpCo Directive.

• Collect every environmental claim: website copy, product pages, packaging, ads, social media, newsletters, and so on.
• Remove product claims like "climate-neutral" if they rely on CO₂ offsetting.
• Make generic terms specific on the same medium or back them with a recognized eco-label. Otherwise, delete them.
• Check the scope: the entire product or just the packaging?
• Make sure that every label is based on a certification scheme or set by public authorities.
• Keep certificates, test reports, and implementation plans on file for every claim.

Conclusion: The EmpCo Directive requires evidence, not buzzwords

The EmpCo Directive doesn't ban environmental advertising. It requires every claim to be true, specific, and verifiable. If you say what actually sets a product apart instead of just calling it "environmentally friendly," you meet the core requirement and give customers more useful information at the same time.

Green promises now need proof, and your copy might need an update. Get in touch through our website or message us on LinkedIn, and we'll run the EmpCo check for your website.

EmpCo Directive: Frequently asked questions (FAQ)

Is there a transition period for the EmpCo Directive?

No, there is no general transition period. The EmpCo Directive has applied across the EU since September 27, 2026, but each member state sets the details in its own national law. In Germany, existing website copy, social media posts, and advertising materials you've already produced are affected as soon as you keep using them. For goods that were placed on the market before September 27, 2026, the new Section 15b UWG applies a special proportionality test to injunction claims until September 2028. That's not a free pass to sell off old stock, and it doesn't apply to digital communication or printed advertising.

Does the EmpCo Directive also apply in B2B?

The outright prohibitions of the EmpCo Directive only apply to communication aimed at consumers. In purely B2B contexts, the general ban on misleading practices under the UWG still applies, and environmental claims are assessed case by case. If your website also reaches consumers, the EmpCo rules apply.

Which sustainability labels are still allowed under the EmpCo Directive?

Under the EmpCo Directive, only labels established by public authorities or based on an independently monitored certification scheme are allowed, for example the EU Ecolabel. There's no official list of permitted labels, so you need to check each one against the directive's criteria.

What are the consequences of violating the EmpCo Directive?

Violations mainly lead to cease-and-desist letters from competitors or associations. If you ignore them, preliminary injunctions and lawsuits for injunctive relief can follow. For widespread infringements, fines of up to €50,000 are possible, or up to 4% of annual revenue for companies with more than €1.25 million in annual revenue.

Who is liable for environmental claims if an agency writes the copy?

A company is responsible for its own environmental claims. Under Section 8(2) UWG, injunction claims also reach copy that an agency writes on its behalf, even if the company wasn't aware of the violation. So have specific claims, wording, and labels reviewed by your legal counsel before publishing.

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