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Clarification

EmpCo still applies: Green Claims Directive vs. EmpCo

A common mix-up is quietly costing merchants their prep time: the Green Claims Directive was stopped. EmpCo was not. Here’s what actually applies, with the source.

As of: 07/19/20264 min read

Key takeaways

  • What was withdrawn is the Green Claims Directive, not EmpCo.
  • The EmpCo directive (2024/825) still applies, unchanged.
  • In Germany it is already transposed into the UWG. Source: Federal Law Gazette I, 19 Feb 2026.
  • Enforced from 27 September 2026.

What was actually stopped?

The EU had two separate initiatives on environmental claims: the Green Claims Directive (rules on substantiating environmental advertising) and the EmpCo directive(“Empowering Consumers”). What was politically stopped / withdrawn is the Green Claims Directive. That’s exactly where the mix-up comes from: the sense that “the environmental-label thing” is off.

The expensive misread

Anyone who concludes from the stopped Green Claims Directive that EmpCo is moot won’t prepare, and will stand on 27 September 2026 without the mandatory notice and with copy a competitor can act on.

What still applies? EmpCo.

The EmpCo directive is already in force and must be transposed into national law. Germany has done so: the UWG amendments that anchor the ban on blanket environmental claims and the information duties are enacted.

Legal basis

Directive (EU) 2024/825 (EmpCo) · Third UWG Amendment Act (Germany), Federal Law Gazette I of 19 February 2026

The transposition into the German UWG is enacted; validity from 27 September 2026 is therefore legally secured, independent of the fate of the Green Claims Directive.

Why the mix-up gets expensive

SEO and preparation time is the real bottleneck. Assume nothing is happening and you lose weeks you could have used to adapt your product pages. The obligations hit every EU B2C shop at the same time, and competitors who are prepared can act directly on unprepared shops’ green claims.

What to rely on

  • Legal basis, not rumour: EmpCo (Directive 2024/825) + the enacted UWG transposition.
  • Deadline: 27 September 2026.
  • Concrete obligations: see What changes on 27 September 2026?

Konforma handles this automatically.

Instead of waiting on rumours: Konforma implements the EmpCo obligations automatically and finds the green claims that risk a cease-and-desist.

Coming soon to the Shopify App Store

This page is general orientation, not legal advice.

Questions on this topic

Was the label obligation abolished?

No. What was withdrawn is the separate Green Claims Directive. The EmpCo directive (with the legal-guarantee notice, GARAN label and the ban on blanket environmental claims) still applies.

Why do so many people confuse the two?

Both EU initiatives concerned environmental claims and were discussed around the same time. When the Green Claims Directive was stopped, it created the false impression that “the whole environmental-label thing” was off the table. It isn’t.

When is EmpCo enforced?

From 27 September 2026. In Germany the transposition into the UWG has already happened (Third UWG Amendment Act, Federal Law Gazette I of 19 February 2026).

Be visible before the deadline hits.

Konforma is coming to the Shopify App Store shortly. Until then, the guides walk you through everything that becomes mandatory on the deadline.

Coming soon to the Shopify App Store