EmpCo Compliance: Checkpoints for Your Online Shop

From 27 September 2026, EU Directive 2024/825 (EmpCo) will tighten the rules for environmental claims in both B2B and B2C contexts. Online shops are particularly affected, as they disseminate a wide range of product information and marketing messages. Early review and adaptation are essential to avoid fines and damage to reputation.

Checkpoints for Product Detail Pages

The product detail page is the central location for information and therefore also the main area where violations of EmpCo can occur.

1. Product Title: Generic environmental terms such as “sustainable” or “environmentally friendly” without concrete evidence are not permissible under the Directive.
2. Main Description: What matters is whether all environmental claims are substantiated by recognised certifications (e.g. EU-Bio, GOTS) or measurable data.
3. Material Information: For mixed materials, specifying the percentage of each material creates transparency and enables informed assessment.
4. Certificate Logos: The relevant point is whether certificate logos link directly to the corresponding certification bodies and whether the certificates are current and valid. For example, a product with EU-Bio certification typically has a link to the official EU-Bio database.
5. Detailed Product Information: Comprehensive information presupposes clear details on care instructions, origin and sustainability aspects.

Filters and Categories: Creating Transparency

Filters and categories allow customers to search for products based on specific criteria. It is important to define clear and comprehensible criteria here.

1. “Sustainable” Filter: Use of the “Sustainable” filter presupposes clear criteria, such as compliance with certain environmental standards or the use of recycled materials.
2. “Bio” Filter: Under the Directive, the “Bio” filter is only tenable for products that have been awarded a recognised organic certificate (e.g. EU-Bio, Demeter).
3. “Recycled” Filter: The “Recycled” filter is only substantiable for products that demonstrably contain a high proportion of recycled material (>50%).

Shipping and Packaging: Making Concrete Information Available

Clear and transparent information is also required in the area of shipping and packaging.

1. Shipping Options: Statements such as “carbon neutral shipping” without a transparent methodology for calculating and offsetting CO2 emissions are not permissible.
2. Packaging Materials: What matters is concrete information about the packaging materials used, including the proportion of recycled material and disposal instructions.

Newsletter and Marketing: Pay Attention to Formulations

You must also comply with the EmpCo Directive in newsletters and marketing materials.

1. Newsletter Subject Lines: Generic environmental terms in newsletter subject lines are subject to the same requirements as the rest of the communication.
2. Own “Eco” Labels: In-house “Eco” labels without an external, independent certification system are not permissible under the Directive.
3. Footer Disclaimer: The newsletter footer may contain a note on compliance with the EmpCo Directive.

Legal Aspects: Imprint

1. Imprint FAQ: The FAQ in the imprint may include information on the company’s EmpCo status.

Common Weaknesses: Often Overlooked

1. Alt Texts of Product Images: The alt texts of product images also fall within the scope and may contain misleading environmental claims.
2. PDF Product Data Sheets: PDF product data sheets are subject to EmpCo requirements in the same way.
3. Schema.org Markup: Schema.org markup may also contain terms such as “sustainable” and falls within the scope.
4. Multilingual Versions: All multilingual versions of a website are subject to the same requirements of the Directive.

Consider Judgments and Certificates

1. Current Case Law: Current case law is relevant, in particular the judgment of the German Federal Court of Justice (BGH, I ZR 98/23) on carbon neutral claims. Recognised certificates such as EU-Bio, GOTS or OEKO-TEX 100 serve as a basis for substantiating environmental claims.

These checkpoints help systematically review and document the key risks of your online shop with regard to the EmpCo Directive from 27 September 2026. The legal assessment in each individual case remains the responsibility of you or your legal advisers. Proactively engaging with the requirements can also strengthen your company’s image and your customers’ trust.