Action plan

The EmpCo compliance checklist

You know the rules. Here is the work, in order. Most companies can get through this in a few focused weeks. The deadline is 27 September 2026, and it also covers products already on the market.

Illustration of a seven-row checklist with the first steps ticked in green beside a calendar with the deadline marked, representing an EmpCo compliance plan

The seven steps

Short answer

Inventory your claims. Sort by risk. Fix or drop generic claims. Rebuild climate claims without offsets. Verify every label. Prepare durability information. Train your team and add a sign-off gate. Done before September 2026, you are ahead of most of the market.

Inventory every consumer-facing claim

Packaging, ads, website, product pages, social media, newsletters, shop displays. List every environmental and social claim, including implicit ones: leaves, globes, green colour schemes, nature imagery. Include brand and product names. Trademarks do not exempt them.

Sort claims into risk buckets

Blacklisted practices first, because they are banned without any misleading test: generic claims, offset-based product claims,uncertified labels, part-for-whole claims, legal minimums presented as achievements. Then case-by-case risks: future promises, irrelevant benefits, social claims.

Fix or drop generic claims

For each vague claim, choose: make it specific with a clear explanation on the same medium, prove recognised excellent environmental performance like an EU Ecolabel, or delete it. "When in doubt, spell it out" is the safe default.

Rebuild climate claims

Remove offset-based neutrality claims from products. Keep claims that reflect real lifecycle impact, backed by life cycle assessment. For targets like net zero 2030: publish a detailed plan with measurable milestones and resources, and contract an independent expert for regular verification.

Verify every label

For each badge or logo: who established it? A public authority, or a certification scheme with independent verification, public terms and open access? If neither, remove it. Remember there is no transition period for labels.

Prepare durability information

Display the harmonised legal guarantee notice from 27 September 2026. Show durability guarantee labels where producers offer them. Surface repair scores for smartphones and tablets, software update periods and spare parts information wherever producers provide it.

Train and gate

Train marketing, e-commerce and design teams on the new rules. Add a claims sign-off step to your content workflow. Keep an evidence file per claim: wording, placement, substantiation, owner. That file is your defence when an authority calls.

Who needs to do what

EmpCo obligations by role
If you are a...	Your priorities
Brand / producer	Claims audit, label verification, lifecycle evidence, future-claim plans. Decide on durability guarantees and share durability data with retailers to win shelf preference.
Retailer / webshop	The harmonised notice, durability labels, repair scores and update periods at the point of sale. Plus your own house-brand claims and any green filters or badges on your site.
Marketing agency	Every campaign for EU consumers must pass the new tests. Build the claims checklist into creative review. Flag risky briefs back to clients early.
Fashion / e-commerce	High enforcement attention. Recycled-content claims must match the actual product part. Collection names like 'conscious' need substance behind them.
Non-EU seller into the EU	The rules apply to you fully. Non-EU government labels need certification schemes. Localise claims per the EU rulebook, not your home market's.

Frequently asked questions

How do I make my company EmpCo compliant?

Five moves. Inventory every consumer-facing green and social claim. Kill or fix generic claims. Verify every sustainability label has a valid certification scheme or public authority behind it. Rebuild climate claims without offsets and back future promises with verified plans. Prepare durability, repair and software update information for the point of sale. Aim to finish before 27 September 2026.

Which claims should I check first?

The blacklisted ones, because they need no proof of consumer harm to be illegal. Generic words like eco-friendly and green, offset-based carbon neutral claims, self-invented badges, whole-product claims that only cover part of the product, and legal minimums dressed up as achievements.

What evidence should I keep for green claims?

For every claim you keep: what it says, where it appears, the substantiation behind it, and who signed it off. Life cycle assessments for climate claims. Certification documents for labels. Implementation plans and third-party verification reports for future promises. Authorities can ask for evidence at any time.

What about products already in stores in September 2026?

The rules apply to them too. The Commission accepts practical fixes: stickers that cover or correct claims on packaging, or corrective information at the point of sale. Authorities will consider whether you made reasonable, proportionate efforts.

What happens if we do nothing?

National authorities can order changes, impose penalties and publish decisions. For widespread EU-wide infringements, fines can reach at least 4% of annual turnover in the affected member states. Add private lawsuits, competitor complaints and the reputational cost of a public greenwashing finding.

Keep reading

Banned green claims

Check your wording against the blacklist.

Durability & repairability

The point-of-sale duties in detail.

Timeline & key dates

Plan backwards from 27 September 2026.