What the new EmpCo greenwashing laws mean for your brand

On 27 September 2026, the EU’s Empowering Consumers Directive takes effect. It bans three kinds of environmental claim outright: carbon neutrality based on offsetting, vague claims like “eco-friendly”, and any sustainability label a brand awarded itself. Blacklisted, so there is no balancing test and no defence that the claim happens to be true. Penalties reach 4% of turnover in the market concerned.

It applies to every brand marketing to EU consumers, wherever the company is registered, and nothing is grandfathered. A post from 2021 still on your grid is still marketing. One claim printed on artwork turns up in every product photo you have ever commissioned, so deleting posts never finishes the job while the pack is still in production. Sign-off does not help either: roughly half of what goes live never reaches a central system at all.

A text search of your website will not find it. Most of the exposure is printed inside the image.

The cheat sheet covers the five Annex I points that changed, which claims survive and which have to go, the three structural gaps that appear in almost every group, and a six-step method for auditing your own estate by hand. Plus what one audit of 30,148 live assets found: 1,072 live, EU-facing and making a banned claim.

If you cannot name which of your live assets carry one, it is worth fifteen minutes.