The impact of the EmpCo Directive on packaging — What brands and retailers need to know

Packaging speaks. They tell stories about quality, origin and, increasingly, about sustainability. But as the number of green promises increases, so does skepticism — among consumers, authorities and competitors. The new EU directive EmpCO brings clarity here. Or rather, it forces companies to provide clarity themselves.

Because in future, the following applies: Anyone who talks about sustainability must be able to prove it. And this applies in particular to the point where a lot of brand communication starts — on the product itself.

A new standard for packaging

With the Empowering Consumers for the Green Transition Directive (in short: EmpCo, EU 2024/825), the EU wants to ensure that consumers receive reliable information about the environmental effects of products. Packaging, labels and claims are particularly in focus. What has so far been considered a “nice to have” message or design element will become a possible liability case from 2026.

The list of affected statements is long:
Terms such as “climate-neutral”, “environmentally friendly” or “biodegradable” may only be used in future if they verifiably and transparently proven are. Your own icons or imaginatively designed seals that suggest an environmental impact could also be considered misleading — even if they are well-intentioned. And compensation models, such as the purchase of CO₂ certificates, alone are no longer enough.

In short: Packaging must become more honest. And more specifically.

Why this is relevant for companies — not only legally, but also operationally

What sounds like legal theory in practice concerns very specific questions in product development, marketing and the design process:

• Which statements on existing packaging are critical?
• Which artworks need to be adapted — and which can remain?
• How can this be organized efficiently across many SKUs and brands?

Many companies are now faced with the challenge of taking stock — and ideally before warnings, inquiries from retailers or internal uncertainties arise.

A look at the big picture — and at the details

From our daily work with brands and retailers, we know that only a few have a structured overview of where green claims are used everywhere. They usually slumber in templates, old artworks or below the perception threshold — visually present, legally sensitive.

The EmpCo Directive makes this a specific mandate for action. Because it is no longer enough just to revise product texts or advertising materials. Pack shots, on-pack seals and pictograms should also be put to the test.

What is important now: Clarity instead of chaos

The key lies in systematic recording:
Which terms, icons or seals do we currently use on our packaging?
How often do these statements appear — and in what form?
And: According to EmpCo, which of these statements could fall into the grey area?

These questions cannot be answered with gut feeling alone — they require a data-based, scalable approach. This is exactly where we rely on automation internally.

Preliminary technical test

In order to produce this overview efficiently, we have developed a tool that automatically analyses packaging artworks. It recognizes visual elements such as seals, claims or defined keywords and marks places that could be potentially critical — for example due to known risk terms or uncertified environmental labels.

We are not a substitute for a legal review.
But we provide a reliable basis with which brands can work in a more targeted, faster and more structured way — whether for the next legal review, the revision of existing layouts or as a briefing for external agencies.

Conclusion: If you sort today, you communicate more securely tomorrow

The EmpCo Directive does not force anyone to panic — but it sets clear expectations. In the future, packaging will not only be assessed aesthetically and functionally, but will also be increasingly valued legal and communicative. Anyone who starts dealing with green claims at an early stage not only provides legal certainty, but also strategic leeway.

Because honest, verifiable sustainability statements are not a disadvantage — they are the new standard.

Curious about what such a pre-test could look like in practice?
We are happy to show how our solution can be integrated into existing design processes — in a simple, visual and data-based way. With no extra effort for your team.