Statement on the EU's Empowering Consumers for the Green Transition Directive (EU) 2024/825

A major change is in the works in how the EU regulates sustainability claims and sustainability labels. The EU's Empowering Consumers for the Green Transition Directive (EU) 2024/825 (EmpCo Directive) entered into force in March 2024 and can be enforced in all all EU Member States on September 27, 2026.

This update shares how we are preparing for EmpCo so that getting C2C Certified® will help you prepare for it, too.

What is EmpCo?

Regulating sustainability claims was already part of the Unfair Commercial Practices Directive (Directive 2005/29, in force since 2005). This Unfair Commercial Practices Directive has been amended by the EMPco Directive, which as adopted in March 2024. EmpCo amends the EU Unfair Commercial Practices Directive 2005/29/EC (UCPD) and introduces clearer, stricter rules for sustainability claims and sustainability labels in business-to-consumer (B2C) communications.

EmpCo introduces several important shifts that directly affect how companies are allowed to communicate sustainability, for example:

• Generic environmental claims such as “ecofriendly”, “green”, or “environmentallu friendly” are prohibited unless they are clearly specified in clear and prominent terms on the same medium or with recognized excellent environmental performance (such as ISO 14024 labels).

• Generic and broad terms such as ‘sustainable, ‘conscious’ and ‘responsible’ are considered misleading, even when there is excellent environmental performance, because such claims relate to other characteristics in addition to environmental characteristics, such as social characteristics.

• Sustainability labels are restricted to those based on compliant independent third-party verification schemes or established by public authorities.

• Product-level climate neutrality or reduced impact claims based on carbon offsetting are no longer allowed.

• Forward-looking environmental claims must be credible, transparent, supported by verifiable commitments, and verified by a third-party expert.

In practice, this means companies must move away from broad sustainability messaging and toward precise, evidence-based communication that reflects actual product and/or company performance.

What we are doing to be fully ready for EmpCo

This is a major opportunity for Cradle to Cradle Certified to help companies continue to, and improve, how they communicate sustainability claims. Our certification scheme already has a head start when it comes to meeting EmpCo’s requirements and offers clear guidance to certification holders on how to make verified claims on the basis of certification achievements:

Our program is already set up to align with ISO/IEC 17065.

Given that ISO/IEC 17065 is not only already a central technical norm to ensure impartial and independent third-party verification, but also explicitly named as a technical norm to ensure EmpCo compliance in the directive’s recitals, we proactively submitted our application in January and the audit process began in March this year. In line with the Commission’s stance on the norm, we expect to obtain ISO/IEC 17065 accreditation in time for the September deadline.

Our Green Claims Guidance aligns with EmpCo requirements.

This guidance is designed to support companies in understanding the applicable rules and explains how Cradle to Cradle Certified® can support clear, credible, and substantiated communication to meet the requirements of EmpCo. You can find the Green Claims Guidance available here.

We are expanding the scope of available verified information for certification holders and implemented a new Product Data Report.

In the context of our updated Cradle to Cradle Certified® Product Standard (Version 5.0) and new digital certification platform, we are providing a new Product Data Report of third-party verified data as a tool for new certifications, and improving our product registry to provide more information on specific claimable product achievements for each category of the Product Standard.

Even though these measures all aim to already ensure our EmpCo-readiness, we understand fully well that there is a feeling of confusion and uncertainty regarding the new legal requirements amongst certification holders in the environmental certification market. In addition to our comprehensive measures already taken and underway, we are therefore currently receiving multijurisdictional legal advice on the compliance of our program. This will help us understand whether we can go even further to fine-tune our program for the application of EmpCo in all Member States. Rest assured that if there should be a further need for adjustments, we will do our best to ensure that everything necessary is in place before September 27, 2026.

Version date: 30-04-2026