EmpCo green claims checklist

Use this practical checklist to identify claims that need stronger wording, evidence or governance.

The Empowering Consumers for the Green Transition Directive (EmpCo, ECGT, Directive (EU) 2024/825) applies from 27 September 2026. It strengthens EU rules on environmental claims and sustainability labels in consumer-facing commercial communications. A green claim is only as strong as the evidence that supports its exact wording.

Use the checklist to review claims across product pages, packaging, labels, websites, campaigns and customer communications. It takes each claim through nine practical checks, then shows where action is needed. 

Why this checklist matters 

Environmental claims often sit across several teams. Marketing writes the wording. Product teams hold the data. Procurement manages supplier evidence. Sustainability teams validate the position. Legal and compliance teams carry the risk. 

EmpCo makes the connection between those teams more important. The directive formally covers business-to-consumer commercial practices. B2B-only communications fall outside its harmonised scope, although national rules may differ. [4] 

A B2B company can still face practical exposure through: 

• product labels that consumers can see; 

• consumer-facing websites and online marketplaces; 

• customers that use supplier claims in their own consumer communications; and 

• contractual requests for substantiation from customers, investors or lenders.

How the checklist works 

1. Download the PDF

First, download the PDF and open it. You’ll see that the fields on the checklist table are fillable.

2. Build your claims list

Add one claim per row. Include claims from packaging, product pages, websites, campaigns, labels, reports and sales materials.

3. Answer nine checks

Use Yes, No, N/A or leave the answer blank. A No identifies an issue to investigate. A blank means the claim has not yet been checked.

4. Prioritise action

Use the result section to separate claims that may need immediate removal or rewriting from claims that need better evidence, ownership or review.

The checklist does not provide a legal opinion or a compliance score. It creates a clear starting point for a structured claims review.  

What the checklist covers 

Scope and exposure 

Identify where the claim appears, who can see it, and whether a customer or partner may reuse it. 

Specificity and implied meaning 

Generic terms such as “eco-friendly”, “green”, “sustainable”, “climate positive” and “nature-friendly” can create exposure when the company cannot demonstrate recognised excellent environmental performance relevant to the claim. The review should include imagery, icons, product names and labels. A claim can be explicit or implied by the overall presentation. 

Evidence and substantiation 

Test whether the evidence supports the exact wording, product, audience and scope. A specific claim is not automatically compliant. It still needs accurate, current and appropriate evidence. 

Offsetting and neutrality claims 

Check whether a neutrality or reduced-impact claim relies on carbon credits outside the product’s value chain. EmpCo prohibits claims that a product has a neutral, reduced or positive greenhouse gas impact when the claim is based on offsetting outside that value chain.

Labels and certifications 

Review voluntary sustainability labels, badges and logos. Labels must be based on a certification scheme or established by a public authority.

Future commitments 

Check targets such as “net zero by 2040” or “on the path to climate neutrality”. Future environmental claims require clear, objective, publicly available and verifiable commitments. They also require a detailed and realistic implementation plan, measurable and time-bound interim targets, allocated resources and regular independent verification.  

Who should use it 

This checklist is designed primarily for Mandate Mia, the sustainability director, chief sustainability officer or ESG lead responsible for board, investor and regulatory requirements. 

It also supports sustainability managers, marketing leads, product owners, procurement teams and legal reviewers. 

It is most useful when a company needs to: 

• review a portfolio of existing claims quickly; 

• identify evidence gaps before a campaign or product launch; 

• coordinate marketing, sustainability, product and legal teams; or 

• decide which claims require specialist review. 

What happens after the checklist 

A completed checklist gives the organisation a prioritised claims inventory. The next step depends on the result: 

• Immediate wording review: a generic, offset-based, unsupported label or unsubstantiated future claim needs attention before continued use. 

• Evidence review: the claim may be specific, but the supporting evidence needs to be checked against the product, wording, scope and date. 

• Governance review: the claim needs a named owner, review date and evidence trail. 

• Scope review: the communication may be outside the formal harmonised scope, but customer, national-law or commercial requirements may still apply. 

 Ready to review your claims? 

Download the checklist and use it with your marketing, sustainability, product, procurement and legal teams. If the results show repeated evidence or ownership gaps, book a scoping session with Nexio Projects.

Bring your completed claims table. Nexio Projects can help turn the findings into a practical review plan, evidence process and credible sustainability journey.