How to make your sustainability communications EmpCo-Proof and build trust
From September 27, 2026, sustainability communication in the European Union will face much stricter requirements. The new EmpCo Directive (Empowering Consumers for the Green Transition) raises the bar for how companies communicate environmental and social claims to consumers.
For marketers, sustainability is no longer just about telling a compelling story. It is about proving that story with facts, data, and transparency.
Sustainability as a Strategic Asset
For many organizations, sustainability has become a core part of their strategy, brand positioning, and business model. Companies invest in sustainable products, circular solutions, and initiatives that help consumers make more responsible choices.
When communicated effectively, sustainability can strengthen customer trust, enhance brand reputation, and create competitive advantage.
The End of Greenwashing
At the same time, regulators are increasingly concerned about greenwashing. While marketing has traditionally allowed some room for creative interpretation, sustainability claims must be accurate, transparent, and verifiable.
In the Netherlands, the Authority for Consumers and Markets (ACM) has already provided guidance through its Sustainability Claims Guidelines and has taken action against companies that used vague or insufficiently substantiated claims. The EmpCo Directive takes this a step further by providing a stronger legal framework across the EU.
What Does EmpCo Require?
The goal of EmpCo is to prevent consumers from being misled when making sustainable purchasing decisions. The rules apply to both environmental and social claims.
Key requirements include:
1. Use Specific and Measurable Claims
Avoid vague terms such as “green,” “sustainable,” “eco-friendly,” or “ethical” unless they can be fully substantiated.
Instead, use concrete claims such as:
- “Packaging made from 100% recycled plastic”
- “Product contains 40% recycled materials”
2. Provide Clear Evidence
Sustainability claims must be supported by evidence that is clear, accessible, and understandable.
Additional documentation may be provided through a website, URL, or QR code. Future-oriented corporate claims, such as “net zero by 2040,” require credible implementation plans and proper validation.
3. Consider Implicit Sustainability Messages
The rules apply not only to written claims but also to communication that suggests sustainability indirectly.
Examples include:
- Nature imagery
- Green colors
- Environmental symbols
- Brand names or slogans suggesting sustainability
These elements may also be interpreted as sustainability claims and require justification.
4. No Climate Neutrality Claims Based Solely on Offsetting
Claims such as “climate neutral” cannot be based only on carbon offsets or carbon credits.
Companies should focus on actual emissions reductions within their value chain.
5. Use Trustworthy Certification Labels
Only recognized, independent certification schemes should be used.
Self-created sustainability labels or logos will generally no longer be acceptable unless they are part of a transparent certification system with independent third-party verification.
6. Be Transparent About Product Lifespan
For physical products, companies should also provide clear information about:
- Durability
- Repairability
- Availability of spare parts
- Warranties
- Software updates
Consumers should not be misled about the expected lifespan of products.
The Challenge for Marketers
Some marketers see EmpCo as a limitation on creativity. After all, consumers often make decisions within seconds and prefer simple messages over lengthy explanations.
The real challenge is finding the right balance between creativity and compliance. The most effective sustainability communication will combine engaging storytelling with credible evidence.
Why a Sustainability Communications Audit Is Essential
EmpCo affects far more than product packaging. It impacts:
- Branding
- Advertising campaigns
- Websites
- Social media
- Corporate communications
- Product information
And the rules apply to both existing and future communications.
Organizations should therefore conduct a sustainability communications audit to identify claims that require stronger evidence, clarification, or adjustment before the deadline.
EmpCo as an Opportunity
While some organizations may need to withdraw unsupported claims, companies that genuinely invest in sustainability have an opportunity to strengthen trust and credibility.
EmpCo encourages organizations to improve measurement, monitoring, and transparency. Those that can demonstrate real impact will be better positioned to differentiate themselves and build stronger relationships with customers.
In the end, the directive is not just about compliance. It is about creating more honest, credible, and trustworthy sustainability communication.
Need support on your sustainability communication and build trust? Contact me: [email protected]
