Sustainability Initiatives
View this service
Empowering consumers for the green transition: what businesses need to know
The Empowering Consumers for the Green Transition Directive (EU) 2024/825, also known as the ECGT or EmpCo Directive, introduces new rules governing sustainability claims made to consumers (B2C). The Directive amends the EU Unfair Commercial Practices Directive (UCPD) and expands the list of commercial practices considered unfair.
For businesses, the key shift is towards more specific, evidence-based and verifiable sustainability communications.
Generic environmental claims such as “eco-friendly”, “green” or “sustainable” are now subject to much stricter requirements. In certain circumstances, these claims are prohibited unless the company can demonstrate the recognised environmental performance required to support them.
More generally, B2C sustainability claims need to be specific, substantiated and verifiable. Businesses should be able to clearly demonstrate how a claim was established, what data supports it and what methodology was used, so that the claim can be independently checked against the underlying evidence.
For example, instead of describing a product simply as “sustainable”, a company would make a more specific claim such as “this packaging contains 30% less virgin plastic than our previous packaging”—provided the claim can be substantiated and verified.
In practice, businesses should be prepared to trace a claim back to its underlying data and explain it if challenged by a regulator, NGO or consumer organisation.
The Directive also addresses certain social claims and characteristics. This can include claims relating to working conditions, social responsibility and other social characteristics of a product or business. Examples could include claims such as: “Fair working conditions”, “Ethically produced”, “Fair wages paid to workers”, “Supports local communities”.
Businesses should therefore look beyond traditional “green claims” when reviewing their consumer-facing communications. Social and ethical claims should also be accurate, substantiated and verifiable, with evidence to support what is being communicated to consumers.
The Directive also introduces stricter rules for environmental and sustainability labels. Environmental labels must be based either on a publicly established scheme, such as the EU Ecolabel, or on a certification scheme that meets the requirements set out in the Directive.
Certification schemes are themselves subject to conditions, including requirements around transparency, accessibility and governance, as well as appropriate procedures for monitoring compliance. This means that businesses should not assume that an internally created sustainability logo, badge or label can simply be used to communicate environmental performance.
Companies should therefore review the labels and certification schemes currently appearing on their products and marketing materials and confirm the basis on which they are being used.
The new rules raise practical questions about how businesses should communicate increasingly detailed sustainability information to consumers.
For example, how can a company move from a broad claim such as “sustainable food” to a more specific, data-driven claim such as “30% lower CO₂e emissions” when space on packaging is limited? And how should businesses deal with the use of colours, images and symbols—such as green colours, leaves or nature imagery—that may contribute to an overall environmental message?
The overall impression created for the average consumer can be relevant. Businesses should therefore consider not only the wording of individual claims, but also the visual presentation and context in which those claims appear.
Businesses should:
Normec Verifavia is a leading assurance provider specialising in sustainability. Our verification and assurance services can help you assess whether your sustainability claims or certification scheme meet the requirements of the applicable regulations.
Get in touch: [email protected]
