EmpCo Audit Check your website for greenwashing.

The audit reads every page, every PDF, every annual report. Long documents are analysed in full — not just the first few paragraphs. What is online is seen.

Every high-risk statement is reviewed a second time by a deliberately sceptical counter-check. If the two assessments differ significantly, the passage is flagged for manual review. Single opinions get caught.

Every flagged passage is documented with the verbatim quote from the source. If a quote cannot be found in the text of the page or document, the finding is automatically filtered out and does not appear in your list. This is how invented findings are caught.

The rulebook is based on the EmpCo Directive (EU) 2024/825, its transposition into the German Act against Unfair Competition (UWG, in force since 27 September 2026) and relevant case law. Every assessment cites a specific provision or ruling. No free model interpretation. For labels, the audit checks whether they are based on a recognised certification scheme, such as the EU Ecolabel or Type I environmental labels under ISO 14024. You can always see why something is marked as problematic.

Statements are evaluated in their full context, with the surrounding paragraphs and the visual rendering of the page. No isolated keyword search, but reading that understands what the page actually says.

Every status change and every comment is documented with a timestamp and the person responsible, and can be exported as an audit trail. Compatible with your compliance processes.

Pick any URL from your domain. Sustainability landing page, product page, press release. You decide.

You receive your finding as a protected online report, with quotes, legal references and prioritisation.

If the result is convincing, you commission the audit for the entire website. Fixed price, transparent cost preview before order placement.

The EmpCo Directive (Directive (EU) 2024/825, “Empowering Consumers for the Green Transition”) is an EU law against greenwashing. It amends the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU) and bans misleading environmental claims and unsubstantiated sustainability labels in advertising to consumers. The directive has been in force since March 2024.

The EmpCo Directive has applied bindingly since 27 September 2026. EU member states had to transpose it into national law by 27 March 2026; Germany did so via the Act against Unfair Competition (UWG). There is no transition period for products already on the market – since the cut-off date, all commercial claims must comply with the new rules.

EmpCo affects all companies that market products or services to consumers in the EU – regardless of sector, company size or place of establishment. SMEs and providers from third countries are also covered as soon as they address EU consumers. Pure B2B communication is not directly covered, but is often affected in practice.

Green claims are environmental advertising statements – claims that attribute an ecological benefit to a product, service or company, such as “climate-neutral”, “made from recycled material” or “plastic-free”. The EmpCo Directive governs the conditions under which such green claims to consumers are permitted and which generic claims are banned.

Banned are generic environmental claims such as “eco-friendly”, “sustainable”, “green” or “ecological” that are neither specifically explained nor backed by recognised excellent environmental performance. Also prohibited are climate claims such as “climate-neutral”, “CO₂-reduced” or “climate-positive” that are based on carbon offsetting, sustainability labels without independent certification, and promises about future environmental performance without a realistic, independently reviewed implementation plan.

Only with genuine reduction evidence. “Climate-neutral” remains permitted if the claim is based on actual emission reductions, is robustly substantiated and is explained directly in the advertising. Advertising climate neutrality that relies solely or mainly on carbon offsetting is prohibited. Claims such as “climate-neutral through offsetting” have no longer been allowed since 27 September 2026.

Since 27 September 2026, sustainability labels may only be used with a certified, independently verified basis – or if they were established by a public authority. Self-created logos and labels without transparent, audited criteria must be removed from advertising, packaging and websites.

EmpCo sets a minimum standard and bans misleading environmental claims in general; it has applied since 27 September 2026. The Green Claims Directive (GCD) was planned as a more detailed framework that would have required mandatory external prior verification (“ex ante”) of every green claim. The GCD was stalled in 2025 – EmpCo applies independently of it.

Yes – in June 2025 the European Commission announced its intention to withdraw the GCD, mainly because of the high verification burden for companies. In practice this changes little: the EmpCo Directive still applies and has required every environmental claim to be substantiated since 27 September 2026.

The main risk is cease-and-desist warnings and injunctions from competitors and associations. For widespread infringements with an EU dimension, fines of up to 4% of annual turnover are also possible. Real cases show the scale: the Italian competition authority AGCM fined Shein €1 million for misleading environmental claims, and a German court banned Apple’s “carbon neutral” advertising for the Apple Watch at first instance. Reputational damage and the obligation to correct or withdraw the contested advertising add to this.

Via the Third Act Amending the Act against Unfair Competition (UWG), published in the Federal Law Gazette on 19 February 2026. It essentially entered into force on 27 September 2026, in step with the EU-wide start of application. The banned practices were added to the “blacklist” of commercial practices that are always unfair. A general transition period for existing claims is not provided – all sustainability communication must comply since then.

No, there is no transition period. Since 27 September 2026, all environmental claims – on packaging, websites, in advertising and in online shops – must meet the new requirements. Companies that have not yet reviewed stock and communication materials should do so now.

Inventory all environmental claims and review them without delay – the 27 Sep 2026 cut-off date has already passed. Remove generic claims or back them with evidence, drop non-certified labels, and revise offsetting-based climate claims. A fixed approval process between marketing, legal and sustainability, plus an audit of external communication, is recommended – the 5 steps above summarise the approach.

Not per se, but they are under heavy criticism because their actual climate impact is often hard to measure and sometimes overstated. That is exactly why, since 27 September 2026, the EmpCo Directive has banned advertising a product as “climate-neutral” based solely on offsetting. For companies this means: offsetting can be part of a strategy, but it is no longer sufficient as the sole basis for an environmental claim.

Yes. Unsubstantiated or generic environmental claims are already actionable as misleading under Section 5 UWG (German Act against Unfair Competition) – through competitors and associations. Since 27 September 2026, the EmpCo transposition in the UWG has tightened this further. Evidence must be in place before the claim goes online.

Yes. The rules apply to all claims that are public since the cut-off date (27 Sep 2026) – including legacy pages, product copy and landing pages that have grown over years. This is exactly the core problem: most companies do not know what is written on hundreds of their own pages. An automated audit provides a complete overview within hours.

Manually, several departments read the website page by page, collect claims and match them against evidence – an effort that can quickly reach five figures. An automated EmpCo audit takes over this groundwork: it identifies critical claims with their exact location and rule reference and delivers a prioritised list on which the final legal review can build.

No. A single AI pass is not reproducible – the same page can produce a different result on every run. A robust audit checks every page in several runs, subjects critical claims to a sceptical counter-check and evaluates text and visual presentation together. Only that makes the findings complete and traceable.

Legally, the company is liable; internally, the problem usually sits in the gap between departments working in separate tools. Marketing writes the copy, sustainability supplies the data, legal reviews – but nobody has the full overview of the website. A shared audit as a single source of truth closes exactly this gap.