Regulations
EmpCo and Green Claims what you can say about your product.
The EmpCo Directive (EU) 2024/825 is not a regulation: its new rules are not enforceable against a company until Spain transposes them. Until then, what is enforceable is existing unfair-competition and misleading-advertising law, which already sanctions generic greenwashing. The Green Claims proposal has not been adopted.
- What it regulates
- Environmental claims in communications to consumers
- What it prohibits
- Generic claims, offset-based neutrality and labels without certification
- Since when
- Not enforceable in Spain until there is national law
- Green Claims
- A proposal that is not adopted and whose passage is blocked
Two European texts are often confused: the EmpCo Directive, still awaiting transposition in Spain, and the Green Claims proposal, which has not been adopted. This page explains what each one is. It is general information, not legal advice.
What is the EmpCo Directive?
Directive (EU) 2024/825 on empowering consumers for the green transition amends the rules on unfair commercial practices. It is a directive, not a regulation: its new rules are not enforceable against a company until there is national law. Spain’s deadline to transpose it has passed and the national law is still in progress; the Commission has opened procedures against several Member States, Spain among them. Until Spain transposes it, what is already enforceable is existing unfair-competition and misleading-advertising law, which already sanctions generic greenwashing.
What does it ban?
- Generic environmental claims, such as “eco-friendly” or “environmentally friendly”, unless recognised excellent environmental performance is shown or the benefit is specified in the same message.
- Claims that a product has a neutral, reduced or positive impact on emissions based on offsetting. They may only rest on the product’s actual life-cycle impact.
- Sustainability labels that are not based on a certification scheme or not established by a public authority.
- Claims about the future without a clear, objective, public and verifiable implementation plan.
What about the Green Claims Directive?
It is a Commission proposal from 2023 on substantiating explicit environmental claims. It has not been adopted. On 20 June 2025 the Commission announced its intention to withdraw it, the legislative process is blocked and it has no application date.
What data can you communicate?
A specific data point about the product’s life cycle, such as a carbon footprint calculated with a recognised standard, is the kind of information that can support a concrete claim, provided it is truthful and not misleading. Xain calculates and certifies the footprint with an ISO 14067 methodology verified by LRQA, and does not present offsetting as a way to reduce or neutralise the footprint. More detail in product carbon footprint.
Frequently asked questions
What companies usually ask before getting started.
Can I say a product is carbon neutral because I offset its emissions?
No. The Directive bans offsetting-based claims that a product has a neutral, reduced or positive impact on greenhouse gas emissions. Such claims may only rest on the product's actual life-cycle impact.
Can I say my product is sustainable or environmentally friendly?
Generic claims like these are banned unless recognised excellent environmental performance is shown, or the benefit is specified in the same message.
Does it apply to sales between businesses?
The Directive amends the rules on unfair commercial practices towards consumers. If you sell to businesses, check how the product is communicated to the end consumer.
Keep reading
Regulations
What Spain's Royal Decree 214/2025, the CSRD and ESRS and the environmental claims rules require, who they affect and what footprint data you may be asked for.
Product footprint
Certify your product’s carbon footprint with an ISO 14067 method verified by LRQA, from your technical documentation, with registration and traceability.
PCF versus EPD
Difference between a product carbon footprint (PCF, ISO 14067) and an environmental product declaration (EPD, ISO 14025): what each measures, when to use it.
ISO 14067
ISO 14067 is the standard that sets how to quantify and communicate a product carbon footprint. What it requires, what cradle-to-gate is and how Xain uses it.
Tell us what you want to measure
One product, a catalogue or your purchases. We reply with the next steps.
Contact Xain