Today the Empowering Consumers for the Green Transition Directive (EU 2024/825), known as EmpCo, starts to apply across the European Union. It changes what companies can say about the environmental credentials of the products they sell to consumers, and there is no transition period. If your brand sells merchandise, uniforms, promotional items or packaging made with recycled materials, the claims attached to those products are now held to a stricter standard than they were yesterday.
What changes from today
EmpCo amends two existing pieces of EU consumer law, the Unfair Commercial Practices Directive and the Consumer Rights Directive. It adds a list of practices that are now considered unfair in all circumstances, which means a regulator does not need to prove that a consumer was actually misled.
Generic environmental claims such as "eco-friendly", "green" or "sustainable" are banned unless the company can demonstrate recognised excellent environmental performance relevant to the claim. Sustainability labels are only permitted if they are based on a certification scheme or established by a public authority. A company may no longer make a claim about a whole product when the benefit only applies to part of it, such as calling a bag "made from recycled materials" when only the body fabric is recycled. Claims that a product has a neutral or reduced climate impact because of carbon offsetting are banned. Presenting a legal requirement as if it were a special feature of your product is also banned.
For claims about future performance, such as a target to use only recycled materials by 2030, EmpCo requires a detailed and realistic implementation plan with clear commitments, reviewed by an independent expert.
Why products already in stock are included
The rules apply to how a product is presented to consumers from today onwards, regardless of when it was made or ordered. A tote bag printed in 2024 with "eco-friendly" on its label is subject to the same rules as one produced next month.
This is the point many brands have not yet planned for. Branded merchandise and packaging often sit in warehouses for months or years before they reach a consumer. The European Commission's guidance points to practical corrections for existing stock, such as covering or correcting claims with stickers, or adding corrective information at the point of sale. The sooner that stock is reviewed, the smaller the correction job becomes.
A delayed national law does not buy time
Not every EU country has finished writing EmpCo into its national law. That is not a reason to wait. The directive sets the date from which the rules apply, and most member states already have their laws in place. A brand selling across several European markets will be judged against the national rules wherever its products are sold, and consumer organisations and competitors are able to bring complaints from today.
What a stronger recycled content claim looks like
A claim that holds up under EmpCo is specific, accurate, limited to the part of the product it describes, and backed by evidence you can produce on request.
Compare "Sustainable tote bag" with "Bag body made from 80% recycled PET from post-consumer bottles". The first is a generic claim that is now banned unless you can prove excellent environmental performance. The second tells the consumer exactly which part of the product contains recycled material, what kind, and how much. It is only acceptable if the percentage is true and you can show how it was established.
Certification helps, but only within its scope. A certificate supports the claims it actually covers for the products and sites it actually covers. It does not make a broader claim acceptable.
How Waste2Wear supports your claims
Brands can only make accurate claims if their suppliers give them accurate information. Waste2Wear has built its verification around that need.
For rPET, our patent-pending RA3 method gives an exact percentage of recycled content. We run it in-house every week across multiple production stages. Wessling validated the RA3 methodology in 2021, and brands that want an individual result independently validated can request this from Wessling for a fee.
Waste2Wear holds GRS certification at company level, and our partner factories hold BSCI, GOTS and RDS certification. We provide the documentation behind every claim we support, so your marketing, legal and sustainability teams can see exactly what each figure is based on.
Three things to do this week
First, review every environmental claim currently live on your products, packaging, websites and campaigns, and remove or rewrite anything generic.
Second, check stock that has already been produced but not yet sold or distributed, and plan corrections for anything that no longer meets the rules.
Third, ask your suppliers for evidence tied to the specific products you sell, not general statements about their company.
If you would like help reviewing the claims attached to products made with Waste2Wear materials, contact our team.