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Empowering Consumers Directive (EU 2024/825): Greenwashing Bans, Durability Rules and the DPP

What the Empowering Consumers Directive (EmpCo, Directive (EU) 2024/825) bans from 27 September 2026: generic environmental claims, offset-only "climate neutral", misleading durability and repairability claims — plus the new guarantee label and how the Digital Product Passport supplies the evidence.

Author: myDPP Team

Empowering Consumers Directive (EU 2024/825): Greenwashing Bans, Durability Rules and the DPP

The Empowering Consumers Directive is the EU rule that decides which environmental and durability claims a company may put in front of a consumer — and which ones become illegal. Unlike the stalled Green Claims Directive, it is already adopted and law across the EU, and it applies from 27 September 2026. From that date, phrases like “eco-friendly” with nothing behind them, and “climate neutral” claims resting only on offsetting, are banned outright.

This article explains what the directive actually prohibits, the new information duties it adds on durability and repairability, how it differs from the Green Claims Directive, and where its data overlaps with the Digital Product Passport under the ESPR.

Key takeaways

  • The Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. It entered into force on 26 March 2024, must be transposed by 27 March 2026, and applies from 27 September 2026.
  • It bans generic environmental claims without proven excellent environmental performance, and offset-only “climate neutral” statements.
  • It restricts sustainability labels to those based on a certification scheme or established by a public authority.
  • It targets early obsolescence and misleading durability and repairability claims, and adds pre-contractual information duties — including a new harmonised label for commercial guarantees of durability over two years.
  • EmpCo is not the Green Claims Directive. EmpCo bans the worst practices; the Green Claims Directive would have set out how claims must be proven and verified — and it is currently stalled.
  • myDPP does not make claims, run verification or determine legal compliance. It stores, versions and communicates the verified product data that a defensible claim rests on.

What is the Empowering Consumers Directive?

Its full name is the directive on “empowering consumers for the green transition” (Directive (EU) 2024/825). It does not create a stand-alone regime; instead it amends two existing consumer-protection laws:

  • the Unfair Commercial Practices Directive (2005/29/EC), which governs misleading advertising, and
  • the Consumer Rights Directive (2011/83/EU), which governs the information a trader must give before a sale.

It was published in the Official Journal on 6 March 2024, entered into force on 26 March 2024, and Member States must apply the national rules from 27 September 2026. Because it works through the Unfair Commercial Practices Directive, it applies broadly to business-to-consumer commerce — there is no size threshold shielding small companies from the advertising bans.

The reason for it is a documented market failure. A European Commission study found that around 53 percent of environmental claims in the EU were vague, misleading or unfounded and 40 percent had no supporting evidence at all, while more than 230 different sustainability labels were in circulation with very different levels of rigour. EmpCo is the EU’s first binding response to that.

The banned commercial practices

EmpCo adds new entries to the “blacklist” of practices in the Unfair Commercial Practices Directive that are considered unfair in all circumstances — no case-by-case assessment needed. The most important for product companies:

  • Generic environmental claims — terms such as “eco-friendly”, “green”, “climate-friendly” or “eco” — where the trader cannot demonstrate a recognised, excellent environmental performance relevant to the claim.
  • Whole-product claims based on one aspect — presenting an environmental benefit as covering the entire product or business when it concerns only a certain aspect (for example, “made with recycled material” implying the whole item is recycled).
  • Offset-only “climate neutral” — claiming a product has a neutral, reduced or positive environmental impact where that rests solely on the offsetting of greenhouse-gas emissions.
  • Uncertified sustainability labels — displaying a sustainability label that is not based on a certification scheme or established by public authorities.
  • Legal minimums sold as features — presenting requirements imposed by law on all products in the category as a distinctive feature of the trader’s offer.

Alongside these outright bans, EmpCo expands the list of misleading actions assessed case by case — notably claims about future environmental performance (“net zero by 2035”) that are not backed by clear, objective, publicly available and verifiable commitments with an independent monitoring system.

New rules on sustainability labels

The label rule deserves its own note because it changes what may appear on packaging. From application, a sustainability label may only be shown if it is based on a certification scheme or established by a public authority. Self-invented logos, in-house “eco” seals and unverified third-party marks are no longer allowed. This is a direct answer to the label proliferation the Commission documented — and it means brands must check every mark they display against a genuine, verifiable scheme.

Durability, repairability and the new guarantee label

This is where EmpCo reaches well beyond greenwashing and into product information — and where its overlap with the Digital Product Passport is strongest. Through the amendment to the Consumer Rights Directive, traders must give consumers clearer information before the purchase, and several new practices become misleading:

  • Premature obsolescence — failing to inform consumers about a feature introduced to limit a product’s durability.
  • Unfounded durability claims — presenting a product as having a certain durability (in use time or intensity) that it does not have.
  • Repairability — presenting goods as repairable when they are not, or failing to inform that they cannot be repaired in line with legal requirements.
  • Consumables — inducing consumers to replace or refill consumables earlier than technically necessary.
  • Software updates — withholding that a software update will negatively affect the functioning of goods with digital elements, or how updates affect the product.

The Consumer Rights Directive amendment also introduces a harmonised label to highlight goods that come with a commercial guarantee of durability of more than two years, and requires clearer pre-contractual information on reparability, spare-part availability and repair instructions. For companies, this turns durability and repairability from marketing language into structured, checkable facts.

EmpCo vs the Green Claims Directive — two different instruments

These two are often mixed up. They are complementary but separate:

  • EmpCo (adopted, applies September 2026) bans specific greenwashing practices and sets information duties. It says what you may not do.
  • The Green Claims Directive (proposal, currently stalled) would have set out how an explicit environmental claim must be substantiated with scientific evidence and verified by an accredited body before use. It says how you must prove what you do claim.

So EmpCo already prohibits the vague “eco” claim and the offset-only “climate neutral” claim; the Green Claims Directive would have added the detailed proof-and-verification procedure. Even without the Green Claims Directive in force, from September 2026 an environmental claim must be truthful and demonstrable — which in practice still means holding the evidence.

Timeline at a glance

DateMilestone
6 March 2024Directive (EU) 2024/825 published in the Official Journal
26 March 2024Entry into force
27 March 2026Deadline for Member States to transpose into national law
27 September 2026National rules apply — bans and information duties take effect

EmpCo and the Digital Product Passport

EmpCo and the DPP are different instruments — one governs advertising and pre-sale information, the other is a product data carrier under the ESPR. But they draw on the same underlying facts. Every claim EmpCo touches has to rest on data, and that data is exactly what a Digital Product Passport is built to hold:

  • A “X percent recycled” claim → material composition and recycled content in the DPP.
  • A “climate neutral” or carbon claim → the product carbon footprint, which makes clear whether a figure rests on reductions or on offsetting.
  • A “durable and repairable” claim → durability data, repairability information, spare-part availability and software-update policy.

The QR code or GS1 Digital Link that opens the DPP is also the natural transparency link behind a claim — the place a consumer or an authority can check what the marketing asserts. Structure this data once, at product level and machine-readable, and it serves the mandatory DPP content and the evidence trail EmpCo expects.

An important clarification: the DPP does not replace EmpCo compliance. It does not decide whether a claim is legal, and it does not make the claim for you. It provides the auditable data foundation on which a claim can be substantiated — or on which a company can see that a claim is no longer defensible and should be dropped.

And to be clear about myDPP’s role: myDPP does not create environmental claims, does not run claim verification, and does not determine whether a practice complies with EmpCo. Those judgements belong to the company and, where needed, to accredited verifiers and legal advisers. What myDPP does is store, version and communicate the verified product data — recycled content, carbon footprint, durability, repairability, spare parts, software-update information — so that the facts behind a claim travel with the product through its passport.

What companies should do now

1. Inventory every claim and label

List every environmental claim, sustainability label and durability statement on your packaging, website and advertising. For each, note what evidence currently supports it.

2. Remove the practices that become illegal

Cut generic “eco/green/climate neutral” wording that cannot be proven, drop offset-only neutrality claims, and remove any sustainability label not based on a certification scheme or public authority.

3. Build the durability and repairability data

Document product lifespan, repairability, spare-part availability, repair instructions and software-update policy — the facts EmpCo now expects you to disclose accurately.

Connect each surviving claim to a traceable source and make it accessible through a link or QR code, so the assertion and its proof are one click apart.

5. Use one product-data source

Maintain the DPP content and the claim evidence from a single structured source, so a durability figure or a recycled-content value is stored once and reused across the passport, the label and the advertising.

Frequently asked questions (FAQ)

What does the Empowering Consumers Directive ban?

From 27 September 2026 it bans, among other things, generic environmental claims without proven excellent performance, “climate neutral” claims based only on offsetting, and sustainability labels not backed by a certification scheme or public authority. It also treats undisclosed premature obsolescence and false repairability claims as misleading.

Is EmpCo the same as the Green Claims Directive?

No. EmpCo is adopted and applies from September 2026; it bans specific practices. The Green Claims Directive is a separate proposal, currently stalled, that would have set out how claims must be scientifically substantiated and independently verified.

Does EmpCo apply to small companies?

Yes. Because it works through the Unfair Commercial Practices Directive, the advertising bans apply to business-to-consumer commerce generally, with no size threshold exempting small companies from the prohibitions.

What is the new durability label?

The amendment to the Consumer Rights Directive introduces a harmonised label to highlight products that come with a commercial guarantee of durability of more than two years, plus clearer pre-contractual information on repair and spare parts.

How does the DPP help with EmpCo?

It does not make claims legal by itself, but it holds the verifiable data — recycled content, carbon footprint, durability, repairability — that a claim must rest on, and makes it accessible through a QR code as the transparency link.

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