Directive (EU) 2024/825
The Empowering Consumers for the Green Transition Directive changes what a fashion brand is allowed to say about its products. There is no transition period, and it applies to stock already on the shelf.
EmpCo amends the Unfair Commercial Practices Directive, adding practices that are prohibited outright. In fashion, five matter most.
Generic environmental claims. Terms such as environmentally friendly, eco, green or climate neutral cannot be used unless recognised excellent environmental performance can be demonstrated.
Carbon neutrality based on offsetting. Claims that a product has a neutral, reduced or positive environmental impact because emissions have been offset are prohibited.
Sustainability labels not based on a certification scheme or established by a public authority. Self-declared labels and in-house scoring systems are caught.
Claims about the whole product when only part of it qualifies, and presenting legal requirements as a distinctive feature.
Future environmental performance claims without clear, objective and verifiable commitments, a detailed implementation plan, and independent third-party monitoring.
Most brands audit their sustainability report. The exposure is further forward than that.
Every claim EmpCo touches resolves upstream. Fibre origin, processing, water, labour conditions — the evidence sits at the first mile, with the growers, gins and mills, and it either exists because it was specified when the supplier was nominated, or it does not exist at all. Nobody retrofits a cotton gin in eight weeks.
This is why remediation before 27 September is a communications exercise and everything after it is a sourcing one. Removing an unsupportable claim protects you this season. Being able to make the claim next season is decided at the brief, the material specification and the supplier nomination.
The risk is not only deliberate greenwashing. Greenwishing — claims made in good faith with evidence that was never collected — is assessed on exactly the same basis, because the test is whether the average consumer is misled, not whether the brand meant well.
Four steps
Inventory every environmental claim across product pages, labels, packaging, filters and campaign material.
Assess each against the prohibited practices, separating claims that can be evidenced now from claims that cannot.
Remediate or remove. Withdrawing a claim is cheaper than defending it.
Fix the source. Write the evidence requirement into the brief and the supplier nomination so the claim is available next season.
Last updated: 1 August 2026
Most fashion brands do not know how many of their live environmental claims survive EmpCo. We will tell you, in 30 minutes, for free. No obligation. Just clarity on where you stand and what you need to do next.
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