Green Claims on Packaging: What Companies Need to Know

What the EmpCo Directive is about

EmpCo stands for “Empowering Consumers for the Green Transition”. The EU Directive is intended to better protect consumers from misleading environmental and sustainability claims. The rules apply to communication directed at end consumers within the EU internal market, regardless of where the company offering the product is based.

What Green Claims on packaging mean for companies

One of the key areas covered by the new requirements is environmental claims, often referred to as Green Claims. These include voluntary statements or representations that communicate an environmental benefit or a lower environmental impact. Examples are terms such as “sustainable”, “environmentally friendly”, “green” or “climate-neutral”. Colours, images, symbols, logos or labels may also qualify if they convey an environmental message in their specific context.

This is particularly relevant for packaging: packaging communicates information, conveys brand values and directly influences purchasing decisions at the point of sale. Environmental and sustainability claims therefore reach consumers directly. For new packaging, Green Claims should consequently be reviewed during the development and design process and adjusted where necessary.

Distinguishing generic from specific environmental claims

Generic environmental claims such as “environmentally friendly”, “green” or “ecological” will generally no longer be permitted. An exception may apply if recognised excellent environmental performance relevant to the specific claim can be demonstrated. The term “sustainable” should also not be used as a blanket statement, as sustainability may include social aspects in addition to environmental considerations.

If the specific environmental benefit is explained clearly and prominently on the packaging itself, the statement is not considered a generic environmental claim. However, the statement must be factually correct and understandable. It must also be clearly attributable and supported by robust evidence. In combination with the rest of the packaging design, it must also not create a misleading overall impression.

Claims such as “recyclable”, by contrast, refer to a specific environmental characteristic. They must likewise be appropriate to the actual packaging and substantiated. Coatings, barriers, windows or closures, as well as the collection and recycling systems in the respective target market, may affect recyclability.

Sustainability labels require a reliable basis

Sustainability labels may only be used if they have been established by a public authority in an EU Member State or are based on a certification scheme with transparent criteria and independent verification. For labels introduced by public authorities outside the EU, an appropriate certification scheme is also required if they are to be used in the EU internal market.

Depending on their design, self-created environmental symbols may be regarded as sustainability labels and would be prohibited without such a basis.

Recognised certifications only substantiate the specific aspect they cover. Evidence relating to the origin or supply chain of a material does not automatically demonstrate the sustainability of the entire packaging.

Particular caution with climate claims

The rules are particularly strict when it comes to product-related climate claims. Certain product-related climate claims will expressly no longer be permitted. This applies to claims that a product or packaging has a neutral, reduced or positive climate impact as a result of greenhouse gas offsetting. This includes statements such as “climate-neutral packaging” or “reduced CO₂ footprint” where these are based on offsetting measures outside the value chain.

Claims concerning emission reductions that have actually been achieved within the product life cycle remain possible. However, they must be formulated precisely and supported by robust evidence.

Review existing packaging now

From 27 September 2026, the new requirements will also apply to packaging that has already been produced or is already on the market if it is marketed to consumers using environmental claims or sustainability labels. No general sell-through period is provided for. Companies should therefore review existing packaging now and plan any necessary adjustments.

Our role as a packaging partner

As a packaging manufacturer, we support our customers with technical information on materials, packaging structures, certifications and available documentation. During the development process, we can jointly examine what material, recycling or comparative claims refer to. We can also assess how individual packaging components may influence recovery and recycling.

However, the specific environmental advertising claim must always be assessed in its individual context. The company responsible for the claim remains responsible for its legal review and approval; specialist legal advice should be obtained where necessary.

We also regularly review our own environmental and sustainability communication and develop it further in line with legal and technical requirements. Our aim is to communicate specific benefits transparently and avoid blanket promises.

Communicate clearly, specifically and transparently

The EmpCo Directive introduces stricter rules for environmental claims, sustainability labels and product-related climate claims. Companies that communicate environmental benefits transparently and support them with robust evidence can reduce legal risks while strengthening the credibility of their communication.

Be specific rather than general, substantiated rather than vague – and choose one precise benefit over a sweeping green promise.

Please note: This article is provided for general information only and does not constitute legal advice. Environmental and sustainability claims must always be assessed on the basis of the specific individual case.