Making environmental claims provable.Since September 2026 the burden of proof shifts toward the advertiser.
The EmpCo directive requires environmental claims to be provable. We show why correct data alone is not enough and what a robust proof looks like.
Since 27 September 2026 the EmpCo directive has applied in Germany through the Act Against Unfair Competition. Anyone advertising with environmental claims should be able to substantiate them. Blanket claims such as “sustainable” or “climate neutral” without evidence come under pressure, and the burden of proof shifts toward the advertiser. This affects every company selling in the EU.
Provable, not asserted.What has applied since September 2026.
EmpCo stands for “Empowering Consumers for the Green Transition”, an EU directive against greenwashing. In Germany it has applied since 27 September 2026. It changes competition law: environmental claims made to consumers are meant to be specific and substantiated. Blanket terms such as “environmentally friendly”, “climate neutral” or “eco” move into focus: they are not meant to be used without a basis.
Three points set the direction. First, claims about the entire product are not meant to be made when they only concern a part of it. Second, vague forward-looking promises such as “climate neutral by 2030” without a concrete plan come under pressure. Third, the burden of proof shifts toward the advertiser, who will need to be able to substantiate a claim. Breaches can carry significant penalties.
80 percent recycled material.The number is right, the claim is not.
A PET bottle carries the claim “made from 80 % recycled material”. The number is correct, but it applies to the bottle body. Cap and label contain no recyclate. Without that detail, a correct number turns into a claim open to challenge, because it suggests the whole product consists of 80 percent recycled material.
A robust proof therefore holds more than the number. It says what the claim refers to, which component, at what share. A frequently cited case is “climate neutral” achieved purely through purchased offsets: here too, what counts is what the claim actually covers. In the Digital Product Passport that matters all the more, because whoever looks there wants to know exactly.
Proof needs structure.That is exactly what we deliver.
A proof is only as good as the data behind it. So that the recycled content figure does not stand as a mere assertion, it has to be held in a structured form: which component, what share, which source. With EPCIS 2.0 and GS1 Digital Link these details can be modelled precisely and machine-readably, for people as much as for systems.
benelog supplies the data infrastructure for it. We implement the GS1 standards that make a proof traceable, in the Digital Product Passport and beyond. The legal assessment of a claim is a matter for qualified legal advice, the robust data foundation comes from us.
Let's talk about your evidence.
You now know what a robust proof depends on. Which of your claims need a data foundation, and how that foundation can be modelled, is best clarified in conversation.