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Many companies underestimate how quickly well-intentioned sustainability communication can turn into a compliance risk. With the EmpCo Directive, the EU is significantly tightening requirements: what used to be considered marketing is now becoming a legally verifiable statement. An EmpCo tool helps to safeguard and optimize green claims.

  • GRC
  • Dieser Artikel wurde am 26. June 2026 aktualisiert.
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egulatory pressure on companies to provide robust evidence for their environmental and climate promises is increasing. With the EmpCo Directive, the EU is creating a new framework that specifically targets greenwashing and misleading green claims—having a deep impact on marketing, product communication and compliance.

For marketing managers, this means: Traditional marketing buzzwords are no longer enough. Statements such as "climate-neutral", "environmentally friendly" or "sustainable" will in future be subject to a stricter burden of proof and must be verifiable and clearly substantiated.

We’ll show you what matters now and what new requirements the EmpCo Directive introduces. We’ll also support you with our EmpCo tool in setting up your sustainability communication strategically and in a legally compliant way!

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Would you like to dive deeper into the topic of the EmpCo guideline? Then you’ll find all relevant information here. Alternatively, you can register on our platform and start our free EmpCo scan to quickly and easily safeguard your marketing claims.

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EmpCo Check 2026

EmpCo-Tool 2026

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Why greenwashing becomes a risk due to EmpCo

The EmpCo Directive represents a fundamental shift in marketing communication. Sustainability is no longer an advertising buzzword, but a clearly regulated area with legal consequences.

The starting point is a structural problem. In recent years, the number of “green” statements in marketing has increased significantly, but so has their lack of transparency. The European Commission found that more than half of the environmental claims reviewed were vague, misleading, or not sufficiently substantiated. Around 40% of the statements could not be backed up with robust data at all. This creates an information deficit for consumers and end customers, making sustainable purchasing decisions more difficult—or even impossible.

With EmpCo, the EU is responding directly to this problem and creating a directive that will be binding from 27 September 2026. The aim is to create clear, comparable, and reliable information in the market and to systematically curb greenwashing and misleading green claims. This is not only about classic environmental aspects, but also social issues, product circularity, and governance-related statements.

 

EmpCo Zitat

A key difference compared to previous regulations lies in the consistency and scope of the new requirements. EmpCo does not regulate companies’ conduct itself, but rather the general presentation of products to consumers. This means that all marketing strategies fall under the regulation (ranging from traditional advertising statements and visual language to product names and ESG-related statements). Especially in marketing, this creates new requirements, since implicit messages or visual elements can also be considered a green claim.

Overall, this means a significant change in the way of working in marketing and in the compliance context. Sustainability claims will need to be systematically reviewed, documented, and aligned internally in the future. Without a robust, transparent data basis and a clear methodology, statements can no longer be communicated with confidence. At the same time, reputational risk increases significantly: greenwashing allegations will not only become more frequent, but also more legally enforceable.

An EmpCo check is therefore essential to systematically review sustainability communication and identify gaps at an early stage. Instead of selective individual assessments, this creates a consistent process that documents green claims in a traceable way, prevents greenwashing, speeds up approvals, and simplifies coordination between marketing, sustainability, and compliance. Especially in light of the new requirements, such an approach is less optional and more a sensible component of professional communication and compliance structures. 

Per se prohibitions under EmpCo: What specifically needs to be considered?

With the EmpCo Directive, the EU is not only tightening the general requirements for sustainability communication, but also introducing a new category that is particularly relevant for companies: so-called per se prohibitions.

These fundamentally change how Green Claims are handled. Certain statements and practices will in future be considered inherently inadmissible and not meaningful – regardless of how they are justified or interpreted in individual cases. A subsequent justification or rhetorically strong argumentation without concrete evidence will no longer be sufficient to label a product as “sustainable”. This clearly limits greenwashing for the first time and makes it legally challengeable.

For marketing and compliance managers, this means: It is no longer just about sales-oriented optimization of wording, but about a systematic review of whether certain types of statements are still permissible at all.

The following aspects are particularly relevant:

Broad terms such as "environmentally friendly", "sustainable", "climate-neutral" or "green" are at the heart of the new regulation. Such statements will only be permitted if they are based on a proven and recognized environmental performance and are clearly classified. Without this classification, they are considered misleading – even if individual aspects of the product are in fact more sustainable.

A particularly sensitive area is statements such as "climate-neutral" when they are based exclusively on offsetting measures (e.g., as part of CO2 offsetting). EmpCo aims to curb precisely this practice.

The background: Offsetting does not change a product’s actual emissions, but it is often communicated as if it does. Such claims will in future only be permitted under very strict conditions, but in many cases will be completely prohibited.

Proprietary seals, internal labels, or non-verifiable sustainability markings are coming under particular scrutiny. EmpCo requires clear standards here: Labels must be based on recognized certification systems and be independently verifiable. Anything else quickly falls under the per se prohibitions, as it suggests a trust basis to consumers that is not substantiated—although it may not actually exist.

Selective communication is also viewed critically. If individual positive properties are highlighted while relevant negative impacts are left out, a distorted overall picture is created. Even if the statement is technically correct, it can be considered unfair. EmpCo therefore significantly tightens the requirements for contextualizing claims.

A classic example: Marketing strategies that advertise "sustainable production" even though only the product’s packaging was produced sustainably.

The burden of proof lies with the company. Every green claim must be supported by robust, traceable, and documented data. Internal assumptions, unvalidated calculations, or opaque methodologies are no longer sufficient. What matters is not only the existence of data, but also its traceability and auditability.

The per se prohibitions under EmpCo mark a clear end to previous practice. Sustainability claims will no longer be interpreted case by case, but assessed and compared along clearly defined boundaries. For companies, this means specifically: Certain statements can no longer be optimized; they are simply no longer permissible unless they can be explicitly substantiated.

At the same time, this creates a clear opportunity. Those who structure their communications early, establish transparent verification processes, and consistently align statements with data and reality not only reduce regulatory risks, but also strengthen their credibility in the market.

EmpCo thus forces companies into a new discipline: Fewer empty marketing promises, and more robust statements. And that is where the greater long-term value lies.

EmpCo in practice: How an EmpCo tool helps

An EmpCo tool is not a classic compliance system, nor is it a pure ESG reporting tool. It sits precisely at the interface between marketing, sustainability and law—exactly where claims are created, assessed and approved.

With an EmpCo check, the goal is to make sustainability communication structured and verifiable while not slowing down day-to-day operations. Good tools manage this balancing act: they reduce risks without unnecessarily complicating processes.

The key functions and forms of support provided by an EmpCo tool can be divided into several core areas:

Matchilla - Auflistung EmpCo-Tool-funktionen Structured claim review in line with regulatory requirements
At the core is the systematic assessment of claims. Statements are no longer reviewed ad hoc, but against clearly defined criteria (e.g., specificity, verifiability or regulatory permissibility incl. per se prohibitions).

The check thus involves a structured review process that identifies potential risks and unclear statements at an early stage.

A marketing team is planning a campaign with the claim “climate-neutral product”. In the EmpCo tool, this is automatically flagged as critical because it is based on offsetting. Instead of a manual alignment with multiple departments, the team receives a clear assessment and alternative wording suggestions right away.

Matchilla - Listing EmpCo tool features Workflow and approval processes for marketing & compliance
The EmpCo check includes a structured approval process that involves all relevant stakeholders. Claims go through defined review and approval stages before they are published. This creates a clear, documented decision-making process instead of informal coordination via email or chat.

A product manager creates new packaging copy. This is automatically forwarded to the sustainability and compliance department. Only after approval by both units is the claim marked as “usable” and can go into production.

Matchilla - Auflistung EmpCo-Tool-funktionen Risk assessment and prioritization of claims
Not every claim is equally critical or risky. An EmpCo check assesses statements based on their risk, considering regulatory sensitivity, missing evidence, or the use of generic terms. This allows companies to focus their resources specifically on conspicuous statements.

A company has hundreds of active claims on its website, packaging, and marketing materials. The tool automatically identifies the 20% with the highest risk (e.g., generic ESG statements without evidence) and prioritizes these for revision.

Matchilla - Auflistung EmpCo-Tool-funktionen Support with wording and alternatives
EmpCo tools often go beyond mere review and actively support the formulation of legally compliant statements. Critical terms are identified and replaced with permissible alternatives, or specified and more clearly contextualized.

Instead of “environmentally friendly,” the tool suggests: “Packaging consists of 80% recycled plastic.” This keeps the statement understandable, while also making it regulatorily robust and verifiable.

Important at this point: An EmpCo tool does not replace a legal assessment, but it creates the operational basis for systematically reviewing green claims in the first place. It brings structure to an area that has often been shaped by individual decisions up to now.

Especially under the new regulatory requirements, this point becomes crucial. Because companies must not only communicate correctly, but also be able to prove at any time why a statement is permissible. And that works best with safe wording and statements.

EmpCo Check: Check Green Claims for free

With the new requirements around EmpCo, one thing is clear: sustainability claims can no longer be checked on the side. It takes structure, clear criteria, and a robust data basis to identify risks early.

That’s exactly why we developed our EmpCo Check!

On the Matchilla platform, you can have your existing claims systematically reviewed against the relevant regulatory requirements. The check transparently shows you where potential risks lie, which statements are critical, and where evidence or adjustments will be necessary.

In doing so, we draw on our experience from over 700 ESG matchings for SMEs and corporations and transfer the insights gained to the assessment of sustainability communication.

The result: you receive a clear, structured assessment of your claims, including specific starting points for further development in a legally compliant way.

Using the EmpCo Check is free of charge, non-binding, and takes place within the Matchilla platform in a protected environment.

If you want to know how robust your current marketing communication is, register for free on the platform and start the EmpCo Check!

Go to the EmpCo Check
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Christian Batz VP Digital, igus AG


Matchilla’s approach is brilliant: I no longer have to laboriously research consultancies and software providers and fight my way through countless comparison portals – the right providers, so to speak, come to me – with just a few minutes’ effort. The matching process saves us a lot of resources.

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Heiko Stötzel Global Head Social Responsibility, SSI Schäfer


Searching for suitable ESG service providers via Matchilla is easy and super fast. We got in touch, defined the specifications, and within a few days the results were there. This route provided us with information about providers we hadn’t heard of before. Real added value.

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Alexander Barion Head of Marketing CE, Fidelity International


With Matchilla, we can easily open ourselves up to impulses from new service providers that were previously outside our radar. Our search criteria are matched against a database, but the final recommendations are in the hands of the Matchilla team. The result: high quality and strong service!

Questions about the EmpCo Check

Assessing sustainability claims becomes significantly more complex and individualized due to EmpCo. It is not enough to review individual statements in isolation – what matters is the interplay of the data basis, wording, context, and regulatory classification.

This is exactly where the EmpCo Check comes in: We apply our experience from more than 700 matchings and compliance-adjacent projects to the structured review of your claims. Instead of uncoordinated individual assessments, you receive a clear, transparent process that quickly shows you where specific risks lie and where action is required.

The EmpCo Check on the Matchilla platform is completely free of charge for you, non-binding, and takes place in a protected environment. There is no obligation whatsoever toward us or third parties. You decide at any time how you proceed with the results.

You enter your relevant claims into the check in a structured way and are guided step by step through the assessment. The process is based on the current regulatory requirements relating to EmpCo and greenwashing.

In the end, you receive a clear assessment of which statements are critical, where evidence is missing, and which claims may need to be adjusted.

Yes – and in many cases that’s exactly what makes sense. EmpCo affects not only future campaigns, but also existing statements on websites, packaging, or sales materials.

The check helps you systematically review your current communications and align them early with upcoming requirements.

No. The EmpCo Check does not replace a case-by-case legal review, but it provides the necessary basis for it. You identify risks early and can prepare your claims accordingly before they are legally assessed.

This reduces coordination effort and significantly speeds up internal approval processes.

Simply register on the Matchilla platform and start the EmpCo Check directly.

You get immediate access to the structured assessment of your claims and can adapt your communications step by step to the new requirements.

Start EmpCo Check
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Quality management tool expert

René Kühn is the founder and managing director at Matchilla. With his team, he was able to build one of the best market overviews for GRC, ESG, and QM service providers on the matching and procurement platform.

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