EmpCo Directive: What you need to know

The new EmpCo Directive makes legally compliant sustainability communications mandatory for all EU Member States from the effective date of 27 September 2026.

Find out what opportunities and requirements this creates for providers in the events industry and what it means in practical terms for your listing in the Berlin Convention Finder.

European Union flag with yellow stars in a circle on a blue background.

What is the EmpCo Directive?

The EmpCo Directive (Empowering Consumers for the Green Transition) introduces uniform rules across Europe for sustainability-related communications from 27 September 2026. Its aim is to prevent misleading or unsubstantiated environmental claims (greenwashing) and provide consumers with greater transparency and reliability.

Following the Directive's entry into force on 27 March 2024, EU Member States had two years to transpose it into national law. Mandatory application must begin by 27 September 2026.

Key points at a glance:

  • Applies to all EU Member States
  • In force since: 27 March 2024
  • Transposition into national law: within 2 years
  • Mandatory from: 27 September 2026

Frequently asked questions about the EmpCo Directive

What do you need to change now?

This applies to all communication channels, from websites and social media to brochures and flyers, labels, packaging and online shops, as well as images, videos, symbols and graphic representations. Materials that have already been published should also be reviewed in good time before the 27 September 2026 deadline to ensure they comply with the new requirements. Please note that the new requirements also apply to your listing in the Berlin Convention Finder.

 

Below you will find examples of statements that will no longer be legally permitted and statements that are EmpCo-compliant:

 

Non-compliant
“Our venue is sustainable and environmentally friendly – celebrate green!”

 

Permitted:
Our venue is certified to ISO 20121.
We source 100 % of our electricity from renewable energy and reduce single-use materials through a reusable system. You can find details of the certification and our measures here: [Link]

 

Non-compliant:
“Enjoy a climate-neutral stay at our sustainable conference hotel.”

 

Permitted: 
“We calculate the CO₂ footprint of our hotel operations and continuously reduce emissions (e.g. through energy efficiency and regional supply chains).

Does the EmpCo Directive also apply to your company?

EmpCo applies to all companies that offer their products or services to customers in the EU. The location of the company's registered office is irrelevant.
 

What constitutes an "environmental claim" under EmpCo?

EmpCo defines “environmental claims” as follows:

  • statements made for marketing and sales purposes
  • graphics and images (e.g. leaves, light bulbs, parks)
  • the colour green
  • typical buzzwords such as “sustainable”, “environmentally friendly”, “eco-friendly” and “climate-friendly”. These adjectives may be used, but must be substantiated in detail
  • claims about the future (strategies, visions, etc.)
  • social aspects are also included (e.g. human rights, working conditions, animal welfare)
     
What happens to my sustainability labels and certifications?

EmpCo does not provide a definitive list of “permitted” labels. However, stricter rules will apply to the use of sustainability labels and sustainability certifications in future.

 

The certification must be recognised:

  • established by a public authority
  • verified by an independent third party
  • based on transparent criteria
  • publicly accessible

Non-compliant labels should be removed from all your communications – both online and offline – by 27 September 2026 at the latest.

 

What is expressly not permitted?

  • self-created labels / proprietary labels
  • labels without independent verification
  • certifications that are not transparent or verifiable
  • purely marketing-driven awards without an underlying certification scheme

 

What are the consequences of non-compliance with EmpCo?

If breaches of the EmpCo Directive are identified in online or offline communications, you may face the following consequences:

  • fines
  • formal cease-and-desist notices
  • interim injunctions
  • claims for injunctive relief
  • claims for damages
     

 

Communicate in compliance with EmpCo

To help you review and adapt your communications, we have put together a range of resources for EmpCo-compliant communication.

Please note that the content is intended as guidance only and does not constitute legal advice. We accept no responsibility or liability for its use or for any resulting content.

Blacklist Keywords

Classic environmental buzzwords

  • Green
  • Eco
  • Environmentally friendly
  • Environmentally responsible
  • Sustainable
  • Resource-efficient
  • Nature-friendly
  • Planet-friendly

Climate and emissions terminology

These terms are considered strong environmental performance claims and should generally be avoided.

  • Climate neutral
  • Carbon neutral
  • Emission-free
  • Low-emission
  • Climate-friendly

Implied environmental superiority

  • Better for the environment
  • Good for the environment
  • Environmentally conscious
  • Conscious consumption
  • Greener travel
  • More sustainable travel

Circularity and future-focused terminology

  • Circular
  • Future-proof
  • Regenerative solution
  • Climate-positive solution
  • Environmentally positive

Implied claims (Even without explicit wording, these can, depending on the context, give the impression of an environmental claim)

  • Green labels/badges
  • Leaves, globes, ticks in an eco-style desi
AI prompt for an EmpCo compliance check

You can use this prompt to review sustainability, environmental and climate-related claims in your communications for potential legal, greenwashing and transparency risks. Simply choose an AI tool and paste the prompt into the text field so the AI knows how to carry out the review.

Important notice
An AI review is intended as initial guidance only and does not replace individual legal advice. The visitBerlin Berlin Convention Office accepts no liability for the accuracy of any content generated.

 

Prompt

You are an interdisciplinary review team consisting of:

a legal expert specialising in sustainability law, EU consumer protection law and German competition law;
an expert in greenwashing and reputational risks; and
an expert in credible sustainability communications.

Review the following communication from a company operating in the events industry.

Type of company:
[Hotel / event venue / catering / incentive / mobility / technology / agency / other]

Communication channel:
[Website / social media / quotation / brochure / presentation / advertisement / other]

Target audience:
[B2C / B2B / mixed]

Statement or communication to be reviewed:
[INSERT TEXT HERE]

Available evidence, data or certifications:
[INSERT DETAILS HERE – if none are known, enter: “no information available”]

Review step 1: Legal risk

Assess the statement against the law applicable at the time of your analysis. At the beginning, state the date on which the legal assessment is current.

In particular, take into account:

  • EU Directive 2024/825 “Empowering Consumers for the Green Transition” (EmpCo) and its implementation into German law;
  • Sections 3, 5 and 5a of the German Act Against Unfair Competition (UWG), as well as the relevant prohibitions in the Annex to Section 3(3) UWG;
  • EU consumer protection law;
  • relevant German case law concerning environmental and climate-related advertising;
  • the current status of the Green Claims Directive – but clearly distinguish between applicable law and proposals that are not yet legally binding.

In particular, check for:

  • general or broad environmental claims such as “sustainable”, “green”, “environmentally friendly”, “ecological”, “climate-friendly” or “resource-efficient”;
  • claims such as “climate neutral”, “CO₂ neutral”, “emission-free”, “Zero Waste”, “climate positive” or comparable absolute claims;
  • claims based on carbon offsetting;
  • claims such as “30% less CO₂”, “more environmentally friendly” or “better for the climate” without a clearly defined basis for comparison;
  • future commitments such as “climate neutral by 2030”, “Net Zero by 2040” or similar targets;
    sustainability labels, certifications and self-created “Green” or “Eco” badges;
  • presenting characteristics that are already legally required as a particular environmental benefit;
  • statements suggesting that an entire hotel, event, offer or company has an environmental benefit when only one individual aspect is actually affected.

Also consider implied environmental claims, for example through the use of green colour schemes, leaves, trees, globe symbols, eco-style ticks, images of nature or designs resembling environmental labels.

Provide the following:

  1. Legal risk:
    low / medium / high
  2. Potentially relevant or problematic legal requirements
  3. Missing evidence or data
  4. Particularly problematic wording or design elements
  5. Potential lower-risk alternatives for further legal review
    Important: Do not invent data, certifications or environmental performance information. Where information is missing, clearly mark it as “evidence required”.

Review step 2: Greenwashing and reputational risk check
Then assess, separately from the purely legal review, how the statement could be understood by guests, customers, event planners, the media, NGOs or competitors.

In particular, consider:

  • Does the statement create expectations that go beyond what the specific measure can reasonably support?
  • Is a single measure being presented as evidence of a broader sustainability performance?
  • Does the wording sound absolute or exaggerated?
  • Could an average guest or customer understand the statement differently from what the company intends?
  • Are relevant limitations or negative aspects omitted?
  • Could the statement easily be picked up by the media or NGOs as an example of greenwashing?
  • Could a claim be legally defensible but still unnecessarily expose the company to reputational criticism?

Provide the following:

  1. Reputational risk:
    low / medium / high
  2. Why the statement could be open to criticism
  3. Particularly critical words or elements
  4. Missing evidence or contextual information
  5. Overall assessment:
    suitable / needs revision / critical

Review step 3: Transparency check
Assess whether readers can clearly understand what has actually been done.
Pay particular attention to the following:

Specificity

Is it clear which specific measure has been implemented?

Example:
Instead of simply saying “We run sustainable events”, use a statement such as:
“For this event, we use reusable tableware only.”

Scope

Is it clear what the statement relates to?

For example:

  • the entire hotel or only its electricity supply?
  • the entire event or only the catering?
  • the entire menu or only individual ingredients?
  • the entire vehicle fleet or only individual vehicles?
  • all events or only a pilot project?
  • the company as a whole or only one location?

Verifiability

Are figures, data, criteria, certifications or other verifiable evidence available?

Comparative claims

For statements using terms such as “less”, “reduced”, “better” or “more efficient”, assess:

  • Compared with what?
  • Over what period?
  • Using which calculation method?
  • For which area or activity?
  • Using which system boundary?

Future claims
For targets such as “climate neutral by 2030”, assess whether there are:

  • specific interim targets;
  • a realistic implementation plan;
  • measurable actions;
  • defined responsibilities and resources;
  • transparent progress reports;
  • any required independent verification.

Provide the following:

  1. Transparency assessment:
    clear / partly clear / unclear
  2. What information is missing?
  3. What misunderstandings could arise?
  4. What specific contextual information should be added?
  5. Specific suggestions for improvement

Finally: improved wording

Provide up to three more specific, lower-risk alternatives based exclusively on the facts that have been provided and can be substantiated.

Prioritise communication about specific measures rather than broad sustainability terminology.

Examples of the intended approach:

Instead of:
“Our sustainable event venue”

Prefer:
“Our event venue has been supplied with 100% electricity from renewable energy sources since [year].”

Instead of:
“Sustainable catering for your event”

Prefer:
“For this catering service, [X%] of the food used comes from [specifically defined region], and [X%] of the menu is vegetarian or vegan.”

Instead of:
“Celebrate with us in a climate-friendly way”

Prefer:
“Our venue can be reached by U-Bahn and S-Bahn; for events, we provide [specific mobility measure].”

Instead of:
“Zero-Waste Event”

Prefer:
“At this event, we use reusable tableware and do not use disposable cups in guest areas.”

Never invent missing facts. If a lower-risk alternative requires additional information, use placeholders such as [percentage], [period], [certification] or [reference value].

Your listing in the Berlin Convention Finder

Your communication about sustainability measures in your Berlin Convention Finder listing is also subject to the EmpCo Directive. Please review your content and update it where necessary. Avoid general or unsubstantiated claims and make sure your sustainability measures are described in specific, transparent terms.

If you have any questions about the Berlin Convention Finder, your listing or your login details, please email us at berlinconventionfinder@visitberlin.de.

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