„Climate neutral“ on a solar module’s product page, „sustainable“ in the category text for vitamin supplements: What has been considered a harmless sales argument for years can trigger a warning letter as of September 27, 2026. We show you which green promises in your shop now need to be reviewed and how to restructure them so they continue to sell.
Formulating environmental claims in online shops correctly according to the EmpCo Directive
Since September 27, 2026, the EmpCo Directive regulates how online shops are permitted to advertise with environmental arguments. This affects not only packaging, but every product text, every category page, and every newsletter that justifies a purchase decision with ecological benefits. Blanket promises such as „environmentally friendly“ or „climate neutral“ are now prohibited in many cases without evidence.
This article puts the new rules into perspective, shows typical problem areas in solar shops and for dietary supplements, and describes a practical review process for your own inventory. It does not replace legal advice in individual cases; the information is current as of October 2026.
New EU rules against greenwashing at a glance
A solar technology retailer has been advertising its modules for years as „climate neutral produced,“ a mail-order retailer for vitamin supplements promises „sustainable sourcing.“ The EU has targeted exactly such statements with Directive (EU) 2024/825. Its official title is „Empowering Consumers for the Green Transition,“ abbreviated as EmpCo. It protects consumers from misleading environmental promises and simultaneously takes action against products that break down sooner than necessary.
For online shops, the first part is particularly important. It affects every advertising statement and thus also product descriptions, filter texts, banners, and social media ads. Much of this comes from manufacturer texts that were adopted without review during import. It is precisely there that the EmpCo Directive has its greatest impact.
Directive rather than regulation
Although the EmpCo Regulation is frequently mentioned, the term is not legally accurate. A regulation applies directly in all member states, while a directive must first be transposed into national law.
For retailers in Germany, it is therefore not the EU text that is decisive, but the amended Unfair Competition Act. The EmpCo Directive thus applies in this country via the UWG.
Distinction from the Green Claims Directive
In parallel, the EU planned a second directive with detailed requirements for how companies must substantiate and verify environmental claims in advance. However, in June 2025, the Commission announced that it would withdraw this proposal. Since then, the initiative has been shelved. This changes little in everyday shop operations, because the EmpCo Directive applies regardless and already contains the decisive prohibitions.
Implementation of the EmpCo Directive in Germany via the UWG
The German legislator implemented the EmpCo Directive with the Third Act to Amend the Unfair Competition Act. The law appeared in the Federal Law Gazette (Part I, No. 43) on 19.02.2026, with its essential parts in effect since 27.09.2026. The law does not provide for a general clearance or transition period for advertising. In essence, the UWG changes at three points:
- New terms: The law defines, among other things, environmental claim, general environmental claim, sustainability label, and recognized outstanding environmental performance.
- Stricter misleading rules: Additional requirements apply to promises regarding future environmental performance and to comparisons.
- Extended black list: The annex to § 3 paragraph 3 UWG contains new business practices that are always prohibited vis-à-vis consumers.
The rules are enforced as before through competition law. Competitors, competition and consumer associations can issue cease-and-desist letters and demand a binding declaration of discontinuance. Online shops are particularly in focus because their texts are public, searchable, and documented with just a few clicks. How strongly EmpCo will shape UWG proceedings in the future will ultimately be decided by the courts.
Incidentally, the warranty label comes from the same EU package and has also been part of the ordering process since the key date. Both obligations can be addressed in one go, provided the shop is being revised anyway.
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Why the new transition period doesn’t help your shop texts
Shortly before the deadline, the Bundestag passed a special rule for existing inventory on 24.09.2026, the new § 15b UWG. If a cease-and-desist claim concerns goods that were put into circulation before the deadline, courts must take good faith and proportionality into account. The rule is limited until September 2028 and only becomes effective upon publication after the Bundesrat has been consulted. It does not create permission to continue selling; it only changes the standard in case of dispute.
Which point weighs more heavily for online retailers? The special rule applies to goods, that is, to imprints on packaging and products. Product descriptions, category pages, meta descriptions, marketplace listings, newsletters and social media posts, on the other hand, are considered advertising. Many retailers hoped that EmpCo would provide transition periods for existing advertising as well, but there is no reprieve for shop texts.
That is why we at VASTCOB recommend reviewing your text inventory independently of your warehouse inventory. Before the rest of the catalog is addressed, pages with high traffic and campaign landing pages should be adapted to the EmpCo Directive.
The black list: These environmental claims are now prohibited
Lawyers refer to the annex of the UWG as the black list, which contains business practices that are without exception impermissible toward consumers. Unlike general misleading conduct, it does not matter whether customers are actually deceived in individual cases. Once a practice is on the list, it is prohibited without a court having to weigh it.
The EmpCo Directive has expanded this list to include several provisions on environmental claims. Five of them occur constantly in shop operations:
| Forbidden practice | Typical shop wording | What is possible instead |
|---|---|---|
| General environmental statement without recognized outstanding environmental performance | „environmentally friendly solar module“ | concrete, proven information in the same text, e.g., on the recycling content of the frame |
| Sustainability seal without a certification system or governmental basis | self-designed „Eco Choice“ badge in the theme | only show independently certified or governmental seals |
| Environmental statement about the entire product, although it only concerns a part | „sustainable capsules“ for a recyclable can | limit the statement to the affected part, e.g., „can made of recyclable aluminum“ |
| Climate neutrality through compensation | „climate-neutral shipping thanks to CO₂ offsetting“ | name own, proven reductions, describe climate protection projects separately |
| Legal obligation as a special feature | „free from prohibited plasticizers“ | omit or mark as a general requirement |
Terms that no longer work without proof
According to the EmpCo Directive, particularly sensitive are terms that claim general environmental performance without substantiating it:
- environmentally friendly, environmentally sound
- ecological, eco, green
- climate-friendly, climate-neutral, CO₂-neutral
- sustainable, nature-friendly
- energy-efficient as a blanket statement
- biodegradable without specifying conditions and timeframe
What is prohibited is not the word itself, but its blanket use. If the text clearly and prominently names the specific environmental performance in the same medium, there is no longer a general environmental claim. However, this information must then be accurate and verifiable.
Durability and repair as the second part of the list
Less well known is that the EmpCo Directive also covers statements about lifespan and repairability.
It is impermissible, for example, to advertise durability that the product does not achieve under normal conditions, or to present a device as repairable when it is not. In shops with electronics, storage devices or wallboxes, information on lifespan and software updates should therefore also be on the checklist.
Which green claims remain permitted?
Environmental arguments remain possible in the shop, but they must be specific, accurate and substantiated. Instead of an overall judgment, a permissible claim describes a measurable property, for example a material content, an energy value or a manufacturing process. Before the claim goes online, the proof should be in place, not only after a cease-and-desist letter.
As an exception, the EmpCo Directive also permits blanket terms, namely when the product demonstrates recognized outstanding environmental performance. This can be achieved, for example, with the EU Ecolabel or with officially recognized environmental labels according to EN ISO 14024.
As long as a seal is based on a certification system with independent monitoring or is established by the state, it may continue to appear.
Be specific instead of making blanket statements
Three typical cases from product texts show what the restructuring can look like. „Environmentally friendly packaging“ becomes „shipping carton made from 100% recycled paper“. Instead of „climate-friendly produced“, the text states what proportion of the electricity at the plant comes from renewable sources, provided the manufacturer can prove this.
„Sustainable product“ gives way to the characteristic that actually makes the difference, such as a refillable container. The more precise the statement, the easier it is to substantiate and the better it withstands the EmpCo Directive.
Future promises with target year
Announcements such as „climate neutral by 2030“ are not prohibited, but are subject to strict conditions. The company needs clear, publicly accessible and verifiable commitments in a detailed, realistic implementation plan that an independent expert regularly monitors. If this plan is missing, the promise is considered misleading under the EmpCo Directive.
Typical pitfalls in solar shops and dietary supplements
Because the environmental benefit seems obvious, texts in product categories that are already considered green easily slip into blanket statements. For over 15 years, we have observed the same pattern in shop projects: the riskiest formulations rarely come from our own marketing, but from manufacturer descriptions and old campaign texts.
For the EmpCo Directive, this makes no difference; the retailer advertising with it is responsible.
Photovoltaics, storage systems and charging stations
Although a solar module generates renewable electricity, it is far from climate neutral. Manufacturing, transport and disposal cause emissions that make a statement like „climate-neutral photovoltaic system“ vulnerable under the EmpCo Directive. Similarly risky are „100% green energy for your home“ on a storage page or „environmentally friendly charging“ for charging stations.
Sustainable instead are concrete, substantiated statements. These include the calculated CO₂ savings of an example system with disclosed calculation basis or the recycling content of frame and packaging.
Dietary supplements and natural products
Around vitamins, protein powders and herbal preparations, environmental claims usually appear in connection with origin and packaging. Formulations such as „sustainably grown“, „plastic-free packaging“ or „climate-neutral shipping“ fall under the EmpCo Directive as soon as they promise an environmental benefit. If the entire packaging actually does without plastic, „plastic-free“ may be permissible. Better replace „sustainably grown“ with the concrete basis, such as organic certification according to the EU Organic Regulation, if available.
Health-related advertising is a separate area of law and continues to be governed by the Health Claims Regulation (EC) No. 1924/2006.
Fashion, cosmetics and household goods
Outside of these two sectors, the EmpCo Directive applies to any product category with environmental arguments. In fashion retail, this mainly affects „sustainable collections“, in cosmetics shops „environmentally friendly formulas“ and for household goods biodegradable cleaners without further details.
How to conduct an EmpCo check in your own shop
The effort of an EmpCo Check lies less in evaluating individual sentences than in finding them. With several thousand articles, environmental claims are distributed across product fields, templates, exports, and emails. A five-step process has proven effective:
- Identify text types: Product and category texts, meta descriptions, image alt texts, banners, theme templates, imported manufacturer texts, marketplace feeds, and newsletter templates.
- Classify statements: What is on the blacklist takes priority over formulations that may only be misleading under certain circumstances.
- Substantiate or rephrase: For each statement, provide evidence, make it more specific, or delete it.
- Check seals: Verify badges and icons in the theme for their certification basis, remove custom creations.
- Regulate approval: Determine who reviews new texts before publication and document changes.
Most forgotten environmental claims enter the shop through automatic product imports, which is consistently confirmed in our 1,000+ successfully implemented customer projects. Manufacturer texts arrive via CSV or inventory management system, and the next import overwrites already corrected descriptions again. For the EmpCo guideline to be permanently complied with, the import rules must also be reviewed.
For WordPress and WooCommerce, we have developed a plugin with FLAVOR Claims that takes over inventory management and sorts findings by risk. However, you should still have borderline cases reviewed by a lawyer, with the findings list from the EmpCo Check serving as a basis for discussion. If import rules, templates, or feeds need to be adjusted, we support you as a WooCommerce agency in the technical implementation.
When consulting on the EmpCo Directive is worthwhile
Two types of support work together when it comes to the EmpCo Directive. Whether a specific statement is permissible in a gray area is assessed by a law firm specializing in competition law. Implementation in the shop, on the other hand, is a matter of craftsmanship: finding findings, reformulating texts specifically, and adapting templates, imports, and feeds so that old statements do not return.
If you are seeking advice on the EmpCo Directive, external support is particularly worthwhile for large product ranges, many imported manufacturer texts, multilingual shops, or sales across multiple marketplaces. Our role lies in the implementation; we leave the legal individual case review to specialized lawyers.
Whether our working method is suitable for your shop can be read in advance on ProvenExpert, where customers transparently and positively rate their experiences with us. For a non-binding conversation about your text inventory, you can reach us via the contact page.
Frequently Asked Questions about the EmpCo Directive
Does the EmpCo Directive also apply to pure B2B shops?
The new prohibitions on the blacklist protect consumers and therefore do not apply to advertising directed exclusively at businesses. However, the general prohibition against misleading conduct under the UWG also applies to B2B business. As soon as private customers can order in the shop, the provisions of the EmpCo Directive apply in full.
May I simply adopt the manufacturer’s environmental claims?
You may adopt them, but you remain responsible. By publishing it in your own shop, the manufacturer’s statement becomes your advertising. Therefore, request evidence and remove claims that cannot be substantiated. For the EmpCo Directive, only whoever advertises to the customer matters.
Do the rules also apply to Amazon, eBay and other marketplaces?
Yes, because a marketplace listing is advertising by the respective seller. The platform only provides the space; you are responsible for titles, bullet points and descriptions. Therefore, also check product texts and product feeds according to the standards of the EmpCo Directive.
Are seals such as the Blue Angel or the EU Ecolabel still permitted?
Yes. The Blue Angel is the environmental label of the German Federal Government, the EU Ecolabel is an official label of the European Union, both are based on independently verified criteria. However, self-designed seals and badges without a certification system are problematic under the EmpCo Directive.
What does a violation cost?
There is no fixed amount for violations of the EmpCo Directive. Typical costs include cease-and-desist letters, a declaration of discontinuance with a contractual penalty for repeat offenses, and the effort to change affected texts at short notice. For widespread, cross-border violations of consumer law, § 5c UWG also provides for fines. You can find an overview of other claimable mandatory information in the guide Legal texts for online shops.
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