Two laws, one survivor
EmpCo vs the Green Claims Directive
The short version
Short answer
The EmpCo Directive (EU) 2024/825 was adopted in February 2024 and applies from 27 September 2026. The Green Claims Directive was a separate proposal for verifying green claims before publication. The Commission withdrew it in June 2025. EmpCo is now the EU's main anti-greenwashing rulebook.
They were designed as a pair. EmpCo tells traders what they cannot say. The Green Claims Directive would have told them how to prove what they do say, with independent verifiers checking claims before they hit the market. The pair became a solo act. The proving duty now flows from the general rules: make a claim, be ready to back it up when an authority asks.
Side by side
| EmpCo Directive | Green Claims Directive (withdrawn) | |
|---|---|---|
| Status | Law. Adopted 28 February 2024, applies 27 September 2026. | Proposal withdrawn by the Commission in June 2025. Never became law. |
| Approach | Bans and restrictions on claims and labels, enforced after the fact. | Pre-market substantiation and third-party verification of claims before use. |
| Legal home | Amends the UCPD and the Consumer Rights Directive. | Would have been a standalone directive. |
| Who enforces | National consumer protection authorities and courts. | Accredited verifiers plus national authorities. |
| What it means for you | Audit claims and labels now. Comply by September 2026. | No pre-approval system. But keep evidence files ready anyway. |
Why the withdrawal raised the stakes
Counterintuitive but true. With the Green Claims Directive gone, there is no formal pre-approval channel that could give a claim a stamp of safety. Every public green statement now lives or dies by EmpCo's bans and the UCPD's misleading test, applied by regulators and judges after publication. That is less predictable, not more relaxed.
Add the timing. National authorities spent years preparing for September 2026. Consumer organisations are watching. The first enforcement wave will look for easy targets: generic claims, offset labels, invented badges. Do not be an easy target.
The rules apply from 27 September 2026
That includes products already on the shelf. Check your claims, labels and product pages now, not after enforcement starts.
Frequently asked questions
Is the Green Claims Directive still happening?
No. The European Commission announced the withdrawal of the Green Claims Directive proposal in June 2025, just before final negotiations. It never became law. The EmpCo Directive, which was already adopted in 2024, is unaffected and applies from 27 September 2026.
What is the difference between EmpCo and the Green Claims Directive?
EmpCo sets the consumer-facing rules: which claims and labels are banned or restricted. The Green Claims Directive would have added a substantiation and verification system, requiring companies to have green claims verified before publication. With its withdrawal, the EU relies on EmpCo plus post-market enforcement by national authorities.
Does the withdrawal of the Green Claims Directive make greenwashing legal?
The opposite. All the EmpCo bans still arrive on 27 September 2026, and the existing Unfair Commercial Practices Directive already covers misleading green marketing today. Companies that relaxed after the withdrawal news are misreading the situation.
Do green claims need pre-approval in the EU now?
No. Without the Green Claims Directive there is no EU-wide pre-market verification of claims. But every claim must still be truthful, specific and provable on request. Authorities can demand evidence after publication, and blacklisted practices are banned outright.
Could a Green Claims style law come back?
Possibly. Withdrawal ends this proposal, not the policy goal. The Commission may revisit substantiation rules later, likely in simplified form. For now, plan around EmpCo and the UCPD.
