Terms like "climate-neutral," "sustainable," and "environmentally friendly" are now an integral part of corporate communications. They can be found on product packaging, websites, in sustainability reports, and in marketing and sales materials from almost every industry. These very statements are now increasingly coming under scrutiny from European legislation.
Directive (EU) 2024/825 “Empowering Consumers for the Green Transition” (EmpCo Directive) The European Union is fundamentally tightening the requirements for communicating environmental and sustainability attributes. This affects all companies – regardless of whether they are based within or outside the European Union – if they offer products or services to consumers on the EU market and advertise with environmental or sustainability claims.
The new regulations aim to protect consumers from misleading environmental claims and increase the transparency and comparability of sustainability-related information. Sustainability communication is thus evolving from a predominantly marketing-driven discipline to a regulatory compliance issue. Companies will henceforth have to ensure that all environmental and sustainability claims are based on reliable, comprehensible, and verifiable evidence and can withstand legal scrutiny.
This has far-reaching implications for existing business processes. In addition to marketing and advertising materials, product labeling, websites, sustainability reports, sales documents, and internal approval and governance processes must be reviewed and, if necessary, adapted. Sustainability communication is thus increasingly becoming a company-wide, cross-functional task that affects marketing, sustainability, legal, compliance, and corporate communications equally.
What exactly the EmpCo guideline changes
A key element of the directive is the fight against greenwashing. Environmental and sustainability claims have become a significant competitive factor in recent years. At the same time, studies by the European Commission have shown that a significant proportion of the environmental claims used were not sufficiently substantiated or comprehensible to consumers. The EmpCo Directive therefore expands upon the existing requirements of the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). It also places greater emphasis on the entire product life cycle. Consumers will be better informed about durability, repairability, and warranty rights. Business practices that encourage the premature replacement of functioning products will be more strictly restricted.
For companies, this means one thing above all: environmental and sustainability statements must in future be reliably documented, comprehensibly justified and verifiable at any time.
This is precisely where structured sustainability reporting can create significant added value. Even though the EmpCo guideline itself does not require a sustainability report, reporting according to the Voluntary Sustainability Reporting Standard (VS) provides a robust basis for documenting ESG indicators, methods, data sources, and responsibilities. This results in a consistent audit trail that helps companies transparently substantiate sustainability claims and reduce regulatory risks.
The most important deadlines
- 27.03.2026: Implementation of the directive into national law by the member states
- 27.09.2026: Mandatory application of the new regulations
Why companies should take action now
Many companies use statements like "sustainably produced," "environmentally friendly," "green," or "CO₂-neutral" without systematically documenting the underlying evidence. This is precisely where the EmpCo guideline comes in. In the future, general environmental claims will only be permissible if they are based on reliable evidence or meet the legally defined requirements. Violations can lead to warnings, fines, legal proceedings under competition law, and reputational damage.
The challenge lies not only in formulating individual advertising claims. Rather, companies must ensure that the underlying ESG data is fully, consistently, and transparently documented. This applies equally to data sources, calculation methods, responsibilities, and internal approval processes.
A sustainability report based on the VS standard helps companies establish precisely these documentation and governance structures. The structured recording of essential sustainability information creates a reliable foundation for customer inquiries, ESG ratings, financing discussions, and providing evidence to authorities and competitors. At the same time, it helps ensure consistency between sustainability reporting and external corporate communications.
Experience from other ESG regulations shows that operational implementation often takes significantly longer than initially expected. Companies that act early reduce regulatory risks, professionalize their ESG governance, and strengthen the trust of customers, business partners, banks, and investors.
Conclusion
While previous ESG regulations often focused on reporting and transparency obligations, the focus is now shifting to the quality and verifiability of external communication. Companies should use the remaining transition period to comprehensively review their sustainability communication, internal processes, and verification structures.
What you should do now
- A complete inventory of all environmental and sustainability statements in marketing, sales, product communication, websites and social media.
- Verification that all statements can be substantiated by reliable ESG data, calculation methods, or recognized certifications or audits.
- Introduction of clear governance and approval processes for sustainability statements.
- Development of structured ESG documentation including data sources, responsibilities and calculation methods.
- Possibly implementing a sustainability report according to the VS standard as a central documentation and verification basis for ESG data and sustainability statements.
- Raising awareness and training employees in marketing, sales, sustainability and compliance regarding the new regulatory requirements.
Our performance promise
At Moore TK, we understand ESG as a success factor – far beyond regulatory reporting obligations. Developments surrounding EmpCo, PPWR, CSRD, ESRS, EUDR, SFDR and the Voluntary Sustainability Reporting Standard (VS) demonstrate that sustainability is increasingly shaping business models, financing options, supply chains and market demands.
We support companies in establishing regulatory-compliant sustainability communications, identifying greenwashing risks early on, and developing the necessary governance, data, and documentation processes. Furthermore, we assist our clients in implementing structured sustainability reporting according to the VS Standard, a practical tool for documenting and substantiating ESG information. This creates the foundation for legally compliant, credible, and consistent sustainability communications, as well as a robust audit trail for customers, business partners, authorities, and other stakeholders.
We would be happy to support you in reviewing your sustainability communications for regulatory risks, evaluating existing green claims, and developing a legally compliant implementation approach. Please feel free to contact us.
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