What you should know about the EmpCo Directive.

The EmpCo Directive (EU 2024/825) is an EU directive on empowering consumers for the green transition. In Germany it was transposed through the Third Act amending the UWG (Germany's Act against Unfair Competition), promulgated in the Federal Law Gazette (BGBl. I 2026 No. 43). The amended UWG rules on misleading environmental claims apply for the most part from 27 September 2026.

The new rules apply from 27 September 2026 in Germany. Until then, companies have time to bring their communications into line.

Yes, the EmpCo Directive applies to all companies regardless of size. SMEs with a website that uses environmental terms are affected too.

EmpCo (EU 2024/825) governs consumer information and prohibitions. The Green Claims Directive (GCD) additionally governs the substantiation of environmental claims and is still going through the EU legislative process.

Generic environmental terms such as „climate-neutral“, „sustainable“, „eco-friendly“, „green“ or „ecological“ are prohibited without concrete, measurable substantiation on the same web page. Particularly strict: „climate-neutral“ based on CO₂ offsetting is a per-se prohibition.

A per-se prohibition means the infringement is established automatically — without any case-by-case assessment. For „climate-neutral“ based on offsetting, the prohibition is absolute, regardless of whether offsetting actually took place.

No. Sustainability labels that are not based on a recognised certification scheme are not permitted under the amended UWG (Annex to § 3 (3) No. 2a). It must be a recognised, externally verified label.

Only if there is a publicly accessible, detailed implementation plan that is regularly verified by independent third parties. Without such a plan, the future-oriented claim is prohibited.

No, offsetting itself is not prohibited — but advertising as „climate-neutral“ based on offsetting is. You may continue to offset, but you may not communicate it as „neutrality“.

Yes, both terms are per-se prohibitions when they are based on offsetting. Variants such as „carbon-neutral“, „greenhouse-gas-neutral“ or „GHG-neutral“ fall under the same rule.

Only with a recognised certificate (Fairtrade International, GEPA, WFTO, GoodWeave). Generic claims such as „fair production“ without substantiation are prohibited from 2026. Claims of „fair wages“ also require supply-chain audits in line with the German Supply Chain Due Diligence Act (LkSG).

Enforcement and penalties follow the national law of each EU member state. In Germany — the first member state to transpose the directive — infringements are pursued under the UWG: injunctive relief (§ 8 UWG), damages (§ 9 UWG) and cease-and-desist warning letters (§ 13 UWG), with an administrative fine under § 19 UWG of up to €50,000 (German law, not applicable in other member states). The EmpCo Directive (EU 2024/825, applying from 27 September 2026) additionally sets a statutory maximum of up to 4% of the annual turnover generated in the EU Member State concerned, enforceable only in EU-wide coordinated CPC proceedings (Art. 21 Regulation 2017/2394); national transposition in other member states is still pending.

Cease-and-desist warnings can be brought by competitors, the competition watchdog association, qualified consumer associations (e.g. vzbv, Deutsche Umwelthilfe) and chambers of industry and commerce (IHK).

A cease-and-desist warning is a legal matter — assessing it belongs in the hands of qualified legal professionals. Empcora is purely a checking service and not legal advice: we identify findings and the relevant legal basis, but we do not provide any recommendation on how to handle a cease-and-desist warning.

Concrete, measurable and substantiated claims remain permitted. Example: „Packaging made from 87% recycled material (ISO 14021)“ instead of „sustainable packaging“. Recognised labels (EU Ecolabel, Blue Angel, etc.) may continue to be used.

Labels with independent third-party verification are recognised: EU Ecolabel, Blue Angel, FSC, PEFC, GOTS, OEKO-TEX, Fairtrade, Cradle to Cradle, EMAS, ISO 14001. Company-owned labels without external verification are prohibited.

With the Empcora free check: enter your URL and our tool automatically crawls your website and flags problematic terms as findings, each with the relevant legal basis. Empcora is purely a checking service (not legal advice).

The free check (1 page, 3 claims) is free of charge. Monitoring Basic (1 domain, 100 pages) costs €19/month, Monitoring Pro (1 domain, 1,000 pages) €59/month, and Agency (25 domains, multi-user, white-label) €499/month.

An audit for an average website (50–100 pages) takes roughly 5–10 minutes with Empcora. You receive the full PDF report immediately afterwards by email or download.

The PDF report contains: compliance score (A–F), statistics (prohibited / substantiation required / OK), findings per page with a status pill, the legal classification per claim, the required substantiation, the legal basis (UWG provision) and a legal disclaimer. Empcora is purely a checking service and does not provide rewrites or recommendations for action.

Yes. The crawler checks headlines (h1–h4), paragraphs, lists, meta description, meta keywords, og:title, og:description, twitter:title, twitter:description and image alt texts.

On a monitoring plan, your website is automatically re-scanned at the interval you choose (daily/weekly/monthly). You receive an email alert when new claims are found or existing ones have been resolved — including a diff table.

With a score of A or B you receive a compliance badge (SVG) that you can embed on your website. It shows potential customers that the automated pre-check found no per-se-prohibited terms — it is not a compliance or legal-certainty guarantee and not a certification. With C/D/E/F you get a different variant (e.g. „substantiation required“).

Yes, on the Agency plan you can manage up to 25 domains in parallel. Multi-user accounts and white-label reports are included in the Agency plan.

Recommendation: monthly on Monitoring Basic, weekly on the Pro plan, daily for agencies. Run an additional manual scan after every major marketing update. Re-scans are included in the plan.

Yes. Upgrades take effect immediately. Downgrades take effect at the end of the current billing period. The Stripe Customer Portal manages everything, including invoices and payment methods.

By default yes: for all anonymous free scans and for non-verified domains, the Empcora crawler strictly observes your robots.txt — Disallow rules and rel="nofollow" are followed. AFTER domain ownership verification (HTTP header, meta tag, .well-known, DNS TXT or automatically via the owner's confirmed account email address), the crawler may ignore robots.txt for that specific domain so that your own compliance scan covers all pages. Competitor scans of third-party sites remain absolutely bound by robots.txt.

No one but you — provided you have added your domain to your account AND released it via ownership verification. As long as this verification is missing, Empcora blocks deep scans („Strict“ mode) or observes your robots.txt („Optional“ mode). Competitors or lawyers therefore cannot quietly probe your site for infringements — the anonymous free check is hard-capped at 5 pages and always respects robots.txt.

Empcora supports four methods — you choose whichever is easiest for you: 1. HTTP header (recommended): your web server or CDN sends the header X-Empcora-Verify with your token on every request. 2. HTML meta tag in the <head> of your homepage. 3. A .well-known/empcora-verify file containing the token. 4. A DNS TXT record at _empcora-verify.<domain>. When you add your domain, a wizard automatically opens with copy-and-paste snippets for nginx, Apache, Cloudflare, WordPress and all common DNS providers. Verification takes a few seconds. In many cases setup is not needed at all: if the domain of your confirmed account email address matches the audited domain (e.g. [email protected] for yourcompany.com), your ownership counts as proven automatically. Freemail addresses such as Gmail or GMX are excluded.

As long as you are not verified, the Empcora crawler follows your robots.txt directives exactly — if crawlers are generally blocked there, the scan result may be incomplete. After ownership verification, the crawler may ignore robots.txt for your own domain — as the owner you have explicitly authorised Empcora to check all pages. This special rule applies exclusively to verified domains and never to anonymous free scans or competitor crawls.

Empcora reads only the publicly accessible HTML content of your pages — like any other crawler or browser. No cookies are set, no forms are submitted and no JavaScript logins are performed. The crawler uses a fixed user agent (Empcora/1.0) and, for verified domains, additionally the X-Empcora-Verified token header — which you can whitelist specifically for Empcora in your Cloudflare/WAF without opening up the user agent globally. SSRF protection automatically blocks internal addresses (127.0.0.1, RFC1918, cloud metadata endpoints). Hosting: Hetzner, Germany; GDPR Article 28 data processing agreement available.