EmpCo Directive: what you will no longer be able to write on your cosmetics and your website from 27 September 2026

You are rereading the product page for your shampoo. “Eco-friendly formula”, “kind to the planet”, and a small green logo your designer drew two years ago. So far, nobody has ever objected.

From 27 September 2026, each of those three lines will have to stand up.

Let us start with the good news: green is not banned. The EmpCo Directive does not ask anyone to stop talking about the environment. It asks you to be able to prove what you claim.

One word of vocabulary, because it will come back. A claim is a statement you write on your product: “natural formula”, “recyclable bottle”, “96 % of plant origin”. Nothing more. And the whole directive turns on a single question: can you prove that sentence?

What is the EmpCo Directive?

Its official name is Directive (EU) 2024/825, known as Empowering Consumers for the Green Transition. In the industry, everyone calls it EmpCo.

It does not create a greenwashing police force: it lengthens the list of commercial practices that are prohibited in all circumstances, the same list already used to sanction misleading advertising. A very practical consequence: your claims will be judged by the enforcement bodies that already exist.

The date of application is 27 September 2026. Several Member States are late in transposing the text into their own law, but that delay does not protect you: get ready for 27 September, and check the national rules of every country where you sell. Not to be confused, in passing, with the “Green Claims Directive”: that was a broader proposal, which the Commission announced in June 2025 that it intended to withdraw. EmpCo has been adopted.

Does this concern my website, or only my labels?

It concerns your website, and that is the most expensive mistake of the moment. EmpCo does not talk about labelling: it talks about everything you say to a consumer in order to sell. So these count just as much as the bottle:

• the product pages, descriptions and category pages of your shop;
• the home page and the “Our approach” or “Our commitments” pages;
• the titles and descriptions displayed in Google;
• banners, newsletters and social media posts;
• catalogues and sales pitches, including those used by your resellers.

Start with the web: a product page can be rewritten in an afternoon, thirty thousand printed cartons cannot. It is the most certainty for the least money.

What about the packaging I have already printed?

EmpCo provides no grace period for selling through existing stock: on 27 September, the rules also apply to products already manufactured and already on the shelf. That does not mean everything has to be destroyed. The Commission asks the authorities to take account of the efforts genuinely made, and corrections are possible, such as a corrective sticker.

The right reflex: identify now the products whose packaging carries a risky statement, and decide before the deadline.

The six changes to know about

1. Vague adjectives

“Ecological”, “green”, “eco-responsible”, “environmentally friendly”, “sustainable”. Used on their own, these adjectives promise a benefit for the planet without saying which one. The directive calls them generic environmental claims, and this is the heart of the matter.

On 27 September, such an adjective is prohibited if you cannot demonstrate that your product is among the very best in its category. The text cites the EU Ecolabel as an example: the exception is reserved for a very small club.

But the word is not banned everywhere. If you specify right next to it what you mean (“ecological because the bottle contains 80 % recycled plastic”), the adjective stops being vague. On one condition: the specification has to be visible and immediately next to the adjective, not in small print.

2. A quality of the pump is not a quality of the product

A quality that concerns only part of the product cannot be presented as if it concerned the whole. Take “100 % recycled plastic”: if the bottle is, but the pump and the cap are made of virgin plastic, the statement is misleading, because the customer understands that the entire pack is. The same problem applies to a single certified ingredient in a formula that is not.

3. Bought carbon neutrality

Reducing your emissions and offsetting them are two different things. Reducing means emitting less. Offsetting means carrying on emitting just as much and paying elsewhere, by planting trees or funding a project, to balance the books.

EmpCo prohibits announcing that a product is climate neutral or climate positive when the claim rests on offsetting. Real reductions, measured in your own production, can still be communicated.

4. Promises for 2030, 2040 or 2050

“We will be carbon neutral in 2030.” This type of commitment is not prohibited, but it must from now on be quantified and made public, rest on a written plan with dated and budgeted milestones, and be verified by an outside expert whose conclusions are published. Put differently: a promise for 2030 is no longer a sentence, it is a dossier.

5. What the law requires of everyone is not a selling point

An obligation the law already imposes on the whole category can no longer be presented as an advantage of your product: if everyone has to do it, it is not an argument. In cosmetics, statements about animal testing need to be looked at very closely. European regulation layers several sets of rules there and does not boil down to “banned since 2013”.

6. In-house logos

You will no longer be able to draw your own badge (“Clean by [brand]”, “Our green commitment”, a leaf in a circle) and present it as a label. There has to be a system behind it: a public set of requirements, open to other companies, monitored by an independent body that can withdraw the label. And the Commission adds a condition that settles a great many cases: that monitoring body must be legally separate from the owner of the sustainability label. A label that audits itself is not a label.

The right reflex: for every logo you display, be able to say who owns the label, who monitors it, and exactly what the certificate covers.

What does not change

Part of the current worry comes from reading the text too broadly. On 27 September you will still be able to talk about the environment, display a genuine certification, communicate measured reductions, and use a plant green or a leaf: according to the Commission, these elements do not in themselves constitute an environmental claim. You will also still be able to publish without having anything validated by anyone: EmpCo creates no prior authorisation. But the evidence has to exist before publication, even if nobody ever asks you for it.

How do you rewrite a sentence that no longer passes?

Three questions are enough to sort almost every sentence on your site. What exactly am I claiming? What am I basing it on: a figure, a test, a certificate? Which part of the product does it apply to: the formula, the bottle, the cap? A documented answer to all three and the sentence stands. If one is missing, it has to be rewritten.

• “Ecological”: no rewrite is possible, you have to give the actual quality, for example “bottle made of [X] % recycled plastic, excluding cap and pump”.
• “Natural formula” becomes “[X] % ingredients of natural origin, calculated according to [method]”.
• “Biodegradable” becomes “[X] % biodegradable in [Y] days, according to test [name]”.
• “Recyclable bottle” becomes “recyclable in the [X] stream; cap and pump: [what applies]”.
• “CO₂ neutral” becomes “production emissions reduced by [X] % since [year]”.
• “Certified organic” becomes “certified [label], by [body], certificate no. [number]”.

Careful: these rewrites are not automatic authorisations. A claim has to be accurate, provable and must not mislead the customer. Putting in a figure is not enough. “Biodegradable” is the most fragile of the six: a product that is biodegradable in an industrial composter is not necessarily biodegradable in a river, so you have to be able to say what is biodegradable, under which conditions, according to which test and in how long.

In white label, who answers for what?

Whoever sells the product under their own name answers for what is written on it. If your brand is on the bottle, it is up to you to prove your claims, even when the data comes from your manufacturer. They hold it; it is up to you to ask them for it. For each product, ask for:

• the percentage of ingredients of natural origin, and the calculation method;
• the valid certificates, with the body, the number and exactly what they cover, as well as the PIF of each product;
• the material of every element of the pack: bottle, cap, pump, carton;
• recyclability and biodegradability, with the corresponding test;
• what is certified, what is measured during quality control, and what is only marketing.

A manufacturer unable to document your main claims leaves you carrying alone the responsibility for sentences you cannot prove. Being able to supply evidence is becoming a selection criterion, in the same way as price and lead times.

What does a company risk if it does not comply?

The directive does not set the fines itself. Each country decides, with one requirement: penalties that are effective, proportionate and dissuasive. In practice, that ranges from an obligation to withdraw the statement through to a fine, by way of an action brought by a competitor or a consumer association.

This article gives a working method, not legal advice. If your whole positioning rests on a vague adjective, if you sell in several European countries or if you have a large stock of packaging to assess, have your communication reviewed: it costs less than a reprint.

Conclusion: a product page now has to be substantiated

EmpCo does not tell brands to stop talking about the environment. It tells them that every claim must have a precise meaning and evidence behind it.

Your website can be corrected in a few hours; a label printed in tens of thousands of copies, far less easily. So start with the web, work your way up to the packaging, and ask your manufacturers for the data that will turn your promises into provable claims.

About AnyBrand Cosmetic

At AnyBrand Cosmetic, we formulate and fill white-label cosmetics based on ingredients of natural origin, with Ecogarantie certification possible depending on the formula. Our role is also to give you the technical elements that let you communicate without risk: percentages calculated according to an identified method, up-to-date certifications, packaging composition.