Turn sustainability claims into credible, defensible communications.
EmpCo and greenwashing: make every claim count
Green claims now need to stand up to scrutiny
Sustainability claims have moved from marketing language to a matter of legal compliance and consumer trust. The Empowering Consumers for the Green Transition Directive, known as EmpCo, introduces stricter rules for environmental claims, sustainability labels and future environmental commitments communicated to consumers.
The impact reaches across industries and across the organisation. Claims can appear on websites, advertising, packaging, social media, product names, fund materials, labels and corporate communications. Some practices are now prohibited outright; others require stronger substantiation, credible implementation plans or independent third-party verification.
We help organisations understand their exposure, review claims at scale, address priority risks and put the governance, evidence and controls in place to communicate with confidence.
Green claims: from marketing language to legal obligation
Join our EmpCo webinar on 19 October 2026
27 September 2026
New rules applicable in Luxembourg.
5 practices
Treated as unfair in all circumstances under the Luxembourg Consumer Code.
Cross-industry
Relevant wherever sustainability claims are accessible to consumers.
How we can help
- Do you know which sustainability claims could expose your organisation?
- Can you identify and assess your claims at scale?
- Can every environmental claim be supported by the evidence behind it?
- Are your net-zero and transition claims built on a credible plan?
- Is your claims governance designed to prevent greenwashing?
- Do your priority claims require independent verification?
Do you know which sustainability claims could expose your organisation?
EmpCo is broad in reach. It can affect claims about a product, service, brand or business, wherever those claims are accessible to consumers. Exposure may sit across websites, campaigns, labels, packaging, product names, fund materials, social media and documents that remain available online.
We assess how the rules apply to your organisation, products, markets and communication channels. We identify the relevant entities and materials, distinguish prescribed disclosures from voluntarily chosen wording, and map the functions that own or approve the claims.
The outcome is a clear view of where exposure may arise, which materials require attention and what to prioritise now.
Can you identify and assess your claims at scale?
Environmental claims are often dispersed across large volumes of content and repeated in different forms. A document-by-document review can be slow, inconsistent and difficult to maintain.
We help build a consolidated claims inventory, using technology to support the identification and grouping of potentially relevant wording. Our specialists then assess the claims against the applicable requirements, separating practices that may be prohibited outright from those requiring case-by-case analysis. Claims can be prioritised according to regulatory risk, business value and the effort needed to remediate them.
The outcome is a documented, decision-ready view of which claims can be retained, which need to change and which should be withdrawn.
Can every environmental claim be supported by the evidence behind it?
A credible claim must be specific, accurate and proportionate to the evidence available. Problems arise when the scope of the wording is broader than the underlying facts, when labels lack the required basis, or when supporting information is fragmented or outdated.
We review the link between each priority claim and its evidence, help build substantiation files and support changes to wording, scope or presentation. We also bring in the relevant environmental, sector and regulatory specialists where technical evidence needs to be strengthened.
The outcome is clearer communication supported by a traceable evidence base, with decisions and changes documented for future review.
Are your net-zero and transition claims built on a credible plan?
Forward-looking environmental claims receive particular attention under EmpCo. Commitments need to be clear, objective, publicly available and verifiable, and supported by a detailed and realistic implementation plan with measurable, time-bound targets and the resources needed for delivery. The plan must also be regularly verified by an independent third-party expert, with findings made available to consumers.
We help assess whether the claim, targets, roadmap, governance, funding and underlying evidence form a coherent whole. Where needed, we support the development or strengthening of the implementation plan and prepare the organisation for independent verification.
The outcome is a future-facing claim grounded in a plan that can withstand scrutiny.
Is your claims governance designed to prevent greenwashing?
A one-off clean-up will not be enough if new claims continue to be created without consistent review. Marketing, Sustainability, Legal, Compliance, Risk and business teams need a common framework for deciding what can be said, what evidence is required and who approves publication.
We design practical claims governance: ownership and approval roles, a central claims register, evidence and record-retention requirements, review criteria, escalation routes and controls embedded into marketing and product-development processes. We also provide targeted training for senior leaders and teams producing or approving consumer-facing communications.
The outcome is a repeatable process that supports timely communication while reducing regulatory and reputational risk.
Do your priority claims require independent verification?
For certain future environmental performance claims, EmpCo calls for regular verification by an independent third-party expert. Organisations need to determine what should be verified, whether the underlying criteria and evidence are suitable, and how findings will be made available to consumers.
We help organisations assess readiness for verification, including the clarity of the claim, the suitability of the criteria, the completeness of the implementation plan, data and evidence, and the governance supporting ongoing monitoring.
The outcome is greater confidence that maintained claims are supported by credible, objective and transparent review.
