Under EmpCo, green claims on recycled textiles have to be proven rather than stated

We manufacture recycled textiles and build the evidence into every order, so when EmpCo asks a claim to be substantiated, the answer is already on file rather than assembled after the fact.

What EmpCo changes for environmental claims on textiles

EmpCo is the industry shorthand for Directive (EU) 2024/825, Empowering Consumers for the Green Transition. It amends both the Unfair Commercial Practices Directive, 2005/29/EC, and the Consumer Rights Directive, 2011/83/EU, so the change works through rules that already govern how brands communicate with consumers rather than creating a separate rulebook alongside them.

Member states had until 27 March 2026 to transpose it into national law, and it applies from 27 September 2026. From that date, every environmental claim a textile or apparel brand makes about a recycled product is judged against EmpCo's standard rather than against whatever a marketing brief once allowed.

The practical shift is easy to state and hard to ignore. A claim that used to work as a general statement of good intent now has to work as a specific, evidenced statement of fact, and the supplier behind that claim needs to be able to produce the evidence on request.

Reusable products made from post-consumer recycled materials
Recycled textile production for a global brand programme

What EmpCo no longer allows you to say

EmpCo sets out, in practical terms, four things a textile or apparel brand can no longer say without evidence behind it.

Generic environmental claims, words like eco-friendly, green, sustainable, conscious or climate neutral, are not permitted unless they are backed by recognised excellent environmental performance that is relevant to the specific claim being made. A label or a line of copy that simply asserts virtue is no longer enough on its own.

Sustainability labels are only permitted when they have been established by a public authority or are based on a third-party certification scheme, which is a narrower list than most supply chains currently use. A label a brand or a supplier invents itself, however well designed, does not meet that bar. Our guide to which sustainability labels EmpCo still allows sets out how that plays out for recycled textiles.

A brand can no longer describe a whole product, or the company behind it, as environmentally good on the strength of a single aspect. A recycled yarn does not make a whole garment sustainable, and a recycled garment does not make a whole company sustainable, at least not as an unqualified claim EmpCo will allow to stand.

Carbon neutral and climate neutral claims that rest on offsetting are no longer permitted. If the claim depends on purchased offsets rather than on measured reduction, it falls outside what EmpCo treats as substantiated.

What a defensible claim looks like now

EmpCo does not ban environmental claims, only the vague ones. A claim that names a specific material, states a specific percentage, and can point to a specific piece of evidence behind that percentage is exactly the kind of claim the directive is designed to protect, because it gives a consumer something they can check rather than something they have to take on faith.

The difference between a claim that survives scrutiny and one that does not is rarely the ambition of the wording, but almost always the evidence sitting behind it. That is the standard this page, and the wider proof hub it sits within, is built around: specific claims backed by verifiable documentation, rather than general claims backed by nothing more than a supplier's word.

The evidence a recycled-content claim should rest on

EmpCo asks for verifiable evidence behind every environmental claim, and for a recycled content claim on rPET fabric or yarn, that evidence should include three things: a tested result, a third-party certification with a clearly stated scope, and documentation that traces the material back through the supply chain.

The tested result comes from RA3, our patent-pending, in-house method for rPET. RA3 is run weekly across multiple stages of production, and it returns the exact percentage of recycled content. You can read how the RA3 method works for the detail behind the figure. Wessling validated the RA3 methodology in 2021 and will validate an individual result on request for a fee, but does not run RA3. That distinction is worth stating plainly, since the two are sometimes confused.

Certification adds a second, independently governed layer, and the scope matters as much as the certificate itself. GRS, the Global Recycled Standard, is held at company level. BSCI, GOTS and RDS are held at factory level. A claim that names the right certification but the wrong scope is still a weak claim, so it is worth being precise about which level backs which statement. These are the third-party certification schemes EmpCo treats as valid, which is the distinction that separates them from a label a supplier makes for itself.

Traceability closes the loop, connecting the certified, tested material back through the stages of production it passed through, so that a recycled content claim is something a brand can stand behind rather than something it hopes nobody asks about.

Stating environmental performance without overstating it

Environmental performance claims are permitted under EmpCo when they are specific, sourced and stated as a named comparison rather than a general impression.

Recycled polyester made from post-consumer plastic bottles and textiles, compared with virgin polyester, uses 70% less energy and 86% less water and produces 75% less CO₂. Recycled polypropylene made from post-consumer food containers, compared with virgin polypropylene, uses 88% less energy and 46% less water and produces 71% less CO₂.

Those are the kind of figures EmpCo is built to reward. Each one names the material, names what it is being compared against, and can be checked rather than taken on trust. The same figures used without the comparison, as a bare claim that a fabric is simply better for the environment, would fall straight back into the generic claims EmpCo no longer allows.

70%

less energy used

86%

less water used

75%

less CO₂ emitted

Figures for rPET, measured against virgin polyester production

Why the specific material stream matters

A recycled content claim is only as strong as the accuracy of the material behind it, which is why we describe each material stream precisely rather than folding them into a single recycled story.

rPET is made from post-consumer plastic bottles and textiles. rPP is made from post-consumer food containers, and food containers only. rLDPE is made from delivery mailers, a distinct stream from both the rPP used in bags and the rPET used in textiles.

Blurring those streams, describing an rPP bag as coming from mixed household plastic, for example, or letting a mailer claim borrow language from a textile claim, is exactly the kind of imprecision EmpCo is designed to catch. Brands sourcing recycled packaging alongside recycled textiles face a parallel set of questions under PPWR, and our guide for recycled packaging buyers covers that side of the evidence in full.

Related article:

A green leaf can now be an environmental claim

How Waste2Wear builds the evidence in

We manufacture recycled fabric and yarn by the metre and finished products, and the evidence described above is built into both, not offered as an add-on once a brand asks for it. Every rPET order can be backed by an RA3 result, the relevant certification at the correct scope, whether that is GRS at company level or BSCI, GOTS or RDS at factory level, and documentation that traces the material through production.

That evidence is prepared so it can move directly from our file to a brand's own claim documentation, rather than requiring a brand's compliance team to chase it down after the fact. The same standard applies to a single metre of fabric and to a full production run, so a claim is documented in the same way whatever the order size.

Reviewing your claims against EmpCo

EmpCo applies from 27 September 2026, and a claim is judged by the same standard whether a brand prepared for it months ahead or is only reviewing its claims now. The claims on your product pages, hangtags and marketing materials were written under a different set of rules, and they are worth reviewing against EmpCo rather than waiting until a customer, competitor or regulator asks a question you cannot answer with a document.

The suppliers you buy recycled material from decide how much of that evidence exists before you need it, which is the reason to have this conversation now rather than after a claim has already been challenged.

Frequently asked questions

Does EmpCo apply to recycled textile and apparel brands?

Yes. EmpCo, Directive (EU) 2024/825, amends the Unfair Commercial Practices Directive and the Consumer Rights Directive, and it applies to any environmental claim made to consumers, including claims about recycled content, sustainability and environmental performance on textile and apparel products. It applies from 27 September 2026.

Can we still describe a product as eco-friendly or sustainable?

A product can no longer carry that description on its own. Generic claims such as eco-friendly, green, sustainable, conscious or climate neutral are banned under EmpCo unless they are backed by recognised excellent environmental performance relevant to that specific claim, so a specific, evidenced statement that names the material, the percentage and the certification behind it is the safer route.

Are self-declared sustainability labels still allowed?

No. EmpCo only permits sustainability labels that are established by a public authority or based on a third-party certification scheme. A label a brand or supplier creates itself does not meet that standard, regardless of how it looks or what it claims to represent.

What evidence does EmpCo expect behind a recycled content claim?

Verifiable evidence, which for rPET means a tested result such as RA3, a third-party certification with a clearly stated scope, and documentation that traces the material back through the stages of production. A percentage on a specification sheet with nothing behind it does not meet that bar.

What is RA3 and how is it different from certification?

RA3 is our patent-pending, in-house method for rPET, run weekly across multiple production stages, returning the exact percentage of recycled content. Certification, such as GRS, BSCI, GOTS or RDS, is a separate, independently governed layer that confirms process and scope rather than measuring the material itself. Both are part of the evidence, and neither is a substitute for the other.

Can we still make a carbon neutral claim if we buy offsets?

No. EmpCo bans carbon neutral and climate neutral claims that rest on offsetting. A claim about carbon impact needs to be based on measured performance, such as a documented comparison in energy, water or CO₂ against a virgin material, rather than on offset purchases.

Does a certification like GRS cover an entire company or just one factory?

It depends on the certification, and the scope changes what the claim can say. GRS is held at company level. BSCI, GOTS and RDS are held at factory level. Naming the certification without naming its scope is one of the more common gaps in a recycled content claim.

What should we do before EmpCo's application date?

Review the environmental claims on your product pages, hangtags and marketing materials against EmpCo's four restrictions, confirm which of those claims already have RA3 results, certification and traceability documentation behind them, and address the gaps with your suppliers before the application date rather than after it.

Used by the world's leading companies

"There are providers all over the world that process PET into yarns, but we were looking for a fully reliable and certified partner, whom we found in Waste2Wear”

Michiel van der Aa, Chief Commercial Officer, Textaafoam

Get the evidence in place before the claim is questioned

EmpCo does not reward the brands with the longest sustainability statements. It rewards the ones that can connect a specific claim to a specific material, a specific percentage and a specific body of evidence behind it, and that ability starts with the supplier who made the material.

We manufacture recycled fabric and yarn by the metre and finished products, and we build the evidence into every order, an RA3 result giving the exact percentage of recycled content, certification at the correct scope, and documentation that traces the material through production. What you receive is not simply a recycled product but a product you can make a defensible claim about.