EmpCo – Making sustainability claims credible
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EmpCo – Making sustainability claims credible
The EmpCo Directive (Empowering Consumers for the Green Transition, EU 2024/825) and its national implementation in Germany (Third Act Amending the Act Against Unfair Competition (UWG), 02/2026) will regulate so-called green and social claims in a business context starting in September 2026. In the future, terms such as “sustainable,” “climate-neutral,” or “environmentally friendly” may only be used if they are specific, verifiable, and scientifically sound. Sustainability labels will also only be permitted if they are based on an independent certification system.

For many medium-sized companies, this means that what is considered marketing today could represent a legal risk as of September 2026 – whether on websites, packaging, in tenders, or in customer communications. We support you in professionally classifying your existing sustainability communication, identifying critical statements, and structuring your communication so that it is resilient, credible, and in compliance with the EmpCo.
Our Approach
1. Inventorying the Existing Statements
1. Inventorying the Existing Statements
We systematically record where and how your company currently makes environmental and sustainability claims – on your website, in product communication, sales documents, packaging, and to customers. In doing so, we also review which seals, labels, or certificates are used and whether they withstand the requirements of the EmpCo directive.
In the first step, we get an overview: How do you manage all sustainability aspects? Where does your organization stand in the areas of environment, economy, and social affairs? Which topics are already being addressed – and where are there blind spots? To do this, we record the current status along the ZNU fields of action, identify existing structures, processes, and data, and recognize what is missing for a potential certification.
Result: Critical issues are collected – depending on the communication channel.
Typical duration: Depends on the scope; usually within a few days.
2. Risk Assessment
2. Risk Assessment
Based on the EmpCo requirements, we assess from a professional perspective which of your claims are resilient and therefore permissible, where gaps in evidence exist, and where there is a risk.
In the first step, we gain an overview: How do you manage all sustainability aspects? Where does your organization stand in the environmental, economic, and social areas? Which topics are already being addressed – and where are there blind spots? To this end, we record the current state along the ZNU fields of action, identify existing structures, processes, and data, and recognize what is missing for a possible certification.
Result: An overview of which statements pose risks.
Typical duration: Depends on the scope; usually within a few days.
3. Adaptation & Verification
3. Adaptation & Verification
Together, we revise critical statements, sharpen formulations, and build up the necessary documentation. This includes, for example, evidence for environmental claims, the allocation of data sources, or the adjustment of seals and labels.
In the first step, we gain an overview: How do you manage all sustainability aspects? Where does your organization stand in the environmental, economic, and social areas? Which topics are already being addressed – and where are there blind spots? To this end, we record the current state along the ZNU fields of action, identify existing structures, processes, and data, and recognize what is missing for a possible certification.
Result: A list of suggestions, including alternative messages.
Typical duration: Depending on the desired scope, usually within 1–2 weeks.
4. Practical Guide and Training
4. Practical Guide and Training
We will provide you with a practical guide that will enable your team to independently assess in the future which environmental claims are permissible and how new content – such as on packaging, in campaigns, or sales materials – should be reviewed before publication. This creates peace of mind in your day-to-day operations. We would also be happy to visit you for an in-house training session to build up the skills directly within your teams.
Result: A practical communication guide.
Typical duration: Depending on the desired scope, usually within 2–3 weeks.
5. Referral to Legal Audits
5. Referral to Legal Audits
We are happy to arrange legal advice should you require a legal review of your claims for individual campaigns.
Other Standards

Reporting (according to CSRD / VS)
We support you with your reporting.

ZNU-Standard

Carbon footprinting according to GHG Protocol / ISO 14064
We support you with your carbon footprinting.

Establish and improve ratings (e.g., EcoVadis, ESG ratings)
We support you in meeting customer, banking, and ESG requirements reliably and efficiently.
Your contact persons
Do you want to reduce risks from unclear sustainability claims and ensure your claims are compliant with the EmpCo directive? Let's talk for 20 minutes about critical claims, evidence gaps, and the next steps.
Your contact persons
Do you want to reduce risks from unclear sustainability claims and position your claims in an EmpCo-compliant manner? Let's talk for 20 minutes about critical statements, evidence gaps, and next steps.
Your contact persons
Do you want to reduce risks from unclear sustainability claims and ensure your claims are compliant with the EmpCo directive? Let's talk for 20 minutes about critical claims, evidence gaps, and the next steps.

