The rules changed on 27 September 2026, when the EU's Empowering Consumers for the Green Transition Directive (Directive (EU) 2024/825) began to apply. It amends the Unfair Commercial Practices Directive, so an unsubstantiated environmental claim now counts as an unfair commercial practice that regulators can act on. If you make claims about a physical product, what matters is whether the data behind them holds up when someone challenges it.
Key takeaways
- The EU's Empowering Consumers Directive applies from 27 September 2026 and bans environmental claims a company cannot back with evidence.
- Two bans matter most: generic claims like "eco-friendly" without proof of leading performance, and "carbon neutral" claims based on offsetting.
- Substantiating a product claim means product-level data, primary activity data ahead of spend-based estimates, supplier-specific emission factors, and a clear trail from claim to source.
- The rule applies wherever you sell. A manufacturer in Asia selling into the EU is fully in scope, even with no EU operations of its own.
- The exposure lands on the brand and marketing teams who write the claims, and most of them do not hold the data to defend them.
What will change after 27 September 2026?
The Empowering Consumers for the Green Transition Directive, often shortened to EmpCo, tightens what companies can say about their products and adds several practices to the EU's banned list. Three changes carry the most weight:
- Generic environmental claims are banned without proof. "Eco-friendly," "green," and "climate friendly" are prohibited unless you can show recognised, leading environmental performance for the product. A general impression of being good for the planet no longer passes.
- "Carbon neutral" claims based on offsetting are banned. You can no longer state that a product has a neutral or reduced climate impact because you buy offsets. The claim has to rest on the product's actual emissions.
- Sustainability labels need a basis. Self-made badges are restricted unless they come from a certification scheme or a public authority.
One point of accuracy, because it gets confused constantly. EmpCo is not the "Green Claims Directive." That was a separate proposal, and the European Commission moved to withdraw it in 2025. EmpCo is the law in force. It makes unsubstantiated claims illegal, but it does not set a single prescribed data standard or a pre-approval step, so the burden sits with the company to hold evidence that survives a challenge.
Why this catches companies that produce in Asia but sell in the EU
The rule applies based on where you sell, not where you manufacture. If your product reaches a consumer in the EU, you are a trader under EU consumer law and your claims are in scope. A factory in Vietnam, a brand in Singapore, and a supplier network across China and India are all part of a supply chain whose finished product falls under EU rules the moment it reaches an EU buyer. It does not require every supplier to measure and report its own emissions. The company selling into the EU does need supplier-specific, primary emission factors for what it buys, rather than an averaged industry figure, and a way to trace the claim back to them.
The exposure is sharpest here for a few reasons. Manufactured goods carry most of their footprint upstream, in purchased materials and components, so a defensible product claim depends on supplier data, which is the hardest to get. The data most companies already hold, spend-based estimates and industry averages, describes a category rather than the item on the shelf, so it will not substantiate a claim about one product. And the people who write "made from low-carbon materials" usually sit in brand or marketing, while the people who could prove it sit in sustainability or operations. Under EmpCo the claim is the company's legal exposure, so those two functions have to be joined up before the words go on the pack.
Companies across Asia often make the boldest environmental statements and hold the least product-level data to stand behind them. That gap is what EmpCo turns into an enforcement risk.
What emissions data actually substantiates a claim?
A claim about a product needs data about that product. Four things separate a defensible claim from an exposed one:
- Product-level, not company-wide. A corporate carbon footprint cannot substantiate a product claim. You need a product carbon footprint for the specific item, on a recognised method such as ISO 14067 or the GHG Protocol Product Standard.
- Primary data ahead of estimates. The actual quantities of energy, materials, and transport tied to the product are what hold up. Spend-based figures describe a category and are the first thing a challenge pulls apart.
- Supplier-specific emission factors. Because most of the footprint is upstream, the calculation is only as strong as the supplier data feeding it. Factors gathered from the actual producers of your materials make the number specific enough to defend.
- A traceable evidence chain. Every figure should trace back to a source: an invoice, a meter reading, a supplier's data, a calculation with its method recorded. An accurate number that cannot be traced still fails under scrutiny, the same way it fails an audit.
What data each type of claim requires
How to get product-level data across your supply chain
The method is well established. The hard part is collecting primary data from a supply base that spans many suppliers, several tiers, and several languages, most of whom do not report emissions today. That means engaging suppliers in their own language, gathering activity data rather than accepting spend figures, applying supplier-specific factors, and holding the result so it traces back to source. Done once and kept current, the same data supports the product claim, feeds the corporate disclosure, and stands up in an external audit.
How Unravel Carbon helps
Doing this at product level, across a real supply chain, and keeping it defensible is the hard part. That is what Unravel Carbon is built for:
- From bill of materials to a first PCF draft in about 20 minutes. Upload a bill of materials, or describe your product and supply chain in plain language, and AI agents build the product system, materials, and emissions model for you.
- See where the footprint, and the uncertainty, come from. Identify emissions hotspots, check data quality at a glance, and replace estimates with better supplier or primary data as it becomes available.
- Keep every number traceable. Calculations, emission factors, and source data are held in an audit-ready evidence trail, on an engine certified to ISO 14067.
- Already used on real products. Unravel Carbon has supported PCFs including ABB's IEC low-voltage motor and the IKANO Insight BILLY bookcase, at a 100% audit pass rate across assured engagements.
Under EmpCo, that traceability is what makes a product claim defensible when a regulator asks for proof.
Frequently asked questions
Does the EU rule apply to companies based outside the EU? Yes. It applies based on where the product is sold. A company that manufactures in Asia and sells to consumers in the EU is in scope for the claims it makes to them.
Is spend-based carbon data enough to substantiate a product claim? No. Spend-based estimates infer emissions from cost and describe a category average. They are a reasonable start for a first corporate inventory, but not specific enough to defend a claim about one product.
What is the difference between EmpCo and the Green Claims Directive? EmpCo, Directive (EU) 2024/825, is in force and applies from 27 September 2026. The Green Claims Directive was a separate proposal the European Commission moved to withdraw in 2025. Use the EmpCo name for the rules that now apply.
What counts as a recognised method for a product footprint? ISO 14067 and the GHG Protocol Product Standard. A defensible claim is built on one of these, with primary and supplier-specific data behind it.
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