EmpCo/ECGT is live – how to turn compliance into advantage

The moment has arrived

From 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive (EmpCo/ECGT, Directive (EU) 2024/825) is in force.

For retailers, marketplaces and brands selling to EU consumers, this is not a “nice to have”. It’s a hard reset on what you can say, how you can say it, and what proof you must hold – with fines up to 4% of annual turnover and mandatory changes to packaging, labels and digital content.

The directive’s aim is simple: end greenwashing by making sure sustainability claims and labels are credible, transparent and independently verifiable. The practical effect is that vague “eco”, “green” or “sustainable” claims without recognised excellent performance and robust evidence are now effectively illegal in B2C communications.

What EmpCo/ECGT actually changes (in plain English)

EmpCo/ECGT amends the EU Unfair Commercial Practices Directive and sets new rules for environmental claims and sustainability labels aimed at consumers.

Key shifts that matter for commercial and marketing teams:

• Generic green claims are banned unless you can demonstrate recognised excellent environmental performance relevant to the claim, backed by verifiable ESG data.

• Offset‑based “carbon neutral” / “climate positive” claims are out; claims must relate to direct reductions in operational emissions, not purchased credits.

• Self‑created sustainability logos and labels are prohibited unless they come from a public authority or a certified scheme with independent third‑party verification and transparent criteria.

• Future‑performance claims (e.g. “net zero by 2035”) must be supported by clear, objective, publicly available and verifiable commitments with detailed, realistic implementation plans and time‑bound targets.

• No transitional relief: from day one, all environmental claims and labels in B2C contexts – including for products already on shelves – must comply.

Enforcement is real and already visible: recent cases include Volvic being convicted over “carbon neutral” and “100% recycled” claims, SHEIN fined €40m for an unsubstantiated 25% emissions‑reduction claim, and coordinated action forcing airlines to drop offset‑based “green flight” messaging.

Although EmpCo/ECGT is an EU B2C directive, it directly affects UK‑based retailers, marketplaces and brands that sell into the EU, market to EU consumers, or use sustainability labels in the EU. Even if your primary market is the UK, the direction of travel is clear: the CMA’s Green Claims Code and the Digital Markets, Competition and Consumers Act 2024 are moving in the same direction, and EU‑facing operations set the benchmark.

Why this is still a big commercial opportunity

It’s easy to read EmpCo/ECGT as the end of sustainability marketing. Some brands will retreat into “greenhushing” to avoid risk.

But the underlying demand hasn’t gone away:

• Consumers still want to identify and reward genuinely better products and brands.

• B2B buyers, investors and partners increasingly expect credible environmental performance as part of commercial decisions.

• Retailers and marketplaces need to differentiate their assortments and own‑brand ranges on real performance, not vague adjectives.

The difference now is that only evidence‑led claims survive. That creates a clear advantage for organisations that can:

• Measure and benchmark their environmental performance robustly.

• Translate that performance into specific, defensible claims.

• Communicate those claims clearly at the point of decision – on pack, online, in B2B materials.

In other words, EmpCo/ECGT doesn’t kill the opportunity; it professionalises it.

Where most brands get stuck

In practice, three bottlenecks show up again and again:

1. Data fragmentation
   Sustainability data lives in reports, spreadsheets, supplier questionnaires and third‑party ratings. Pulling it together into a coherent, comparable view is slow and manual.

2. Unclear “so what?”
   Teams know they have data, but struggle to turn it into specific claims that are both commercially useful and compliant. “We’re better than average” isn’t enough – better than whom, on what, and proven how?

3. Risk aversion in marketing
   Legal and compliance rightly push back on vague language, but without an alternative playbook, marketing either defaults to generic claims (risky) or says nothing (missed opportunity).

The result: brands either overclaim and risk enforcement, or underclaim and lose differentiation.

How Earthmark streamlines the evidence‑led, substantiation piece

This is exactly the problem Earthmark was built to solve.

Earthmark provides AI‑driven, benchmarked environmental scores and insights for brands, retailers and marketplaces – designed to be:

• Comparable: performance is assessed relative to peers, not in a vacuum.

• Evidence‑led: methodology is aligned with major frameworks and explicitly reviewed against EmpCo/ECGT requirements for substantiation, life‑cycle considerations and fair comparisons.

• Actionable: teams can see where they lead, where they lag, and what to prioritise next.

Crucially, Earthmark holds an average of 103 datapoints per company. That depth matters under EmpCo/ECGT because it lets you move from “we think we’re good” to “here’s exactly where we’re good, against whom, and on what metrics”.

In practice, Earthmark helps teams move through the full journey:

1. Sector‑specific benchmarking down to your closest competitors

Instead of a generic market average, Earthmark lets you:

• Narrow right down to the most relevant peer set for your category and business model.

• See how you perform on material metrics (e.g. carbon intensity, circularity, supply‑chain practices) versus those specific competitors.

• Identify outliers and leaders in your segment, so you know what “recognised excellent performance” looks like in your context.

This is the foundation for claims that are both commercially meaningful and compliant: specific, comparable and defensible.

2. A clear map of “where you can claim now” vs “where to work to get ahead”

Earthmark turns benchmarking into a practical roadmap:

• Claim‑ready strengths: metrics where you already lead or are in the top tier, forming the basis for precise B2C claims (e.g. “top quartile for X in category Y”, “Z% lower carbon intensity vs category average”).

• Improvement priorities: metrics where you lag your closest competitors, highlighting where to focus resources to move from “cannot claim” to “can claim” over time.

• Message guardrails: clear guidance on which types of claims are safe to use under EmpCo/ECGT and which are blacklisted (e.g. generic “eco‑friendly”, offset‑based neutrality claims).

The output is a living, data‑backed narrative: here’s what we can say today, here’s what we’re working on, and here’s how we’ll prove it.

3. Specific, comparable datapoints for sustainability, product and marketing teams

Earthmark arms cross‑functional teams with the information they need to make accurate, comparative, substantiated claims:

• Sustainability teams get a clear view of performance gaps and improvement levers, aligned to reporting frameworks and investor expectations.

• Product and category teams can see which lines or ranges have the strongest environmental profile and where to focus innovation and supplier engagement.

• Marketing and brand teams receive concrete, comparable numbers to use in copy, product pages, FAQs and B2B decks – with a clear audit trail if regulators or partners ask for substantiation.

Because Earthmark is built with EmpCo/ECGT in mind, the datapoints and comparisons are structured to support the kind of evidence the directive expects: verifiable, relevant and non‑misleading.

Turning EmpCo/ECGT compliance into competitive advantage

Rather than viewing EmpCo/ECGT as a burden, retailers, marketplaces and brands can use it to:

• Build trust by replacing vague adjectives with specific, comparable performance.

• Reduce legal risk by grounding claims in robust data and clear methodologies.

• Differentiate in a crowded market where many competitors will either overclaim (and get caught) or underclaim (and disappear).

The new competitive advantage isn’t being the “greenest” in a generic sense. It’s being the most evidence‑led:

• You know exactly where you lead.

• You can prove it with data.

• You can communicate it clearly and confidently in B2C contexts that fall under EmpCo/ECGT – and in B2B conversations that demand the same level of rigour.

A practical starting point

If you’re a retailer, marketplace or brand working through what EmpCo/ECGT means for your claims, packaging and site content, a pragmatic first step is to:

1. Audit your current B2C environmental claims across packaging, PDPs, campaigns and site copy.

2. Map each claim to evidence: what data, certification or methodology supports it, and is that evidence verifiable and relevant under EmpCo/ECGT?

3. Benchmark against your closest competitors to see where your performance is genuinely exceptional and where it’s not.

4. Rewrite claims to be specific, comparable and defensible – and remove or rework anything that relies on generic language or offsets.

5. Embed the process so that new products, ranges and campaigns go through the same evidence‑led check before launch.

Earthmark exists to make steps 2–4 fast and repeatable at scale – arming sustainability, product and marketing teams with the information they need to make accurate, comparative, substantiated claims and to encourage continued competition and transparency across retail and marketplaces.

If you’re working through your EmpCo/ECGT playbook and keen to hear what’s working in practice, reach out to hear how Earthmark supports evidence‑led claims that are resonating with consumers and buyers.