Are you “ECO FRIENDLY” or EmpCO COMPLIANT?

Did you add words like “ECO FRIENDLY” or “ENERGY EFFICIENT” on your website and considered it enough to show you are doing your part in saving the planet? Well, starting from the 27th of September, this type of wording can get you in hot water in the EU and consequently, Romania.

The rules come from Directive (EU) 2024/825, known as the Empowering Consumers for the Green Transition Directive, or EmpCo. It targets vague environmental language, unreliable sustainability labels and climate claims, also adding rules for promises about durability and repair.

Member States had until 27 March 2026 to bring it into national law, with Romania doing so through Government Emergency Ordinance no. 18/2026. The new rules apply from 27 September 2026 to all consumer-facing communication, including websites, social media posts and product labeling.

Since I build and maintain websites for many types of businesses, I read this directive with a practical question in mind: if my clients are using green claims on their websites, how can they align and comply with the new laws and regulations?

So I’ve created a guide that covers what EmpCo says, which parts of your site it reaches and how to rewrite and document your claims so you can keep communicating the real improvements your business makes.

What is the EmpCo Directive?

The EmpCo Directive, formally known as the Directive on Empowering Consumers for the Green Transition (EU) 2024/825, is an EU legislative measure designed to protect consumers from misleading environmental claims and labels. As part of the European Green Deal, the Directive amends the existing:

• Unfair Commercial Practices Directive (UCPD, Directive 2005/29/EC) which governs misleading and aggressive practices towards consumers;
• and the Consumer Rights Directive (CRD), which sets the information you must give consumers before they buy.

Because both are consumer protection laws, EmpCo applies to commercial practices connected with promoting, selling and supplying products to consumers. A website that sells exclusively to other businesses sits in a different position from a consumer-facing shop. If your website speaks to both audiences, treat every environmental claim a consumer can see as covered.

The problem EmpCo responds to is well documented. In a 2020 screening of websites, with results published in January 2021, the European Commission and national consumer authorities examined 344 environmental claims in detail. In 42% of cases the authorities had reason to believe the claims were exaggerated, false or deceptive, in 59% the trader had not made supporting evidence easily accessible, and in 37% the claim relied on vague wording such as “eco-friendly”, “sustainable” or “conscious”.

In Romania, the directive is transposed through Government Emergency Ordinance no. 18/2026, adopted on 19 March 2026 and published in the Official Gazette (Monitorul Oficial) no. 236 on 26 March 2026. It amends Law no. 363/2007 on unfair commercial practices and Government Emergency Ordinance no. 34/2014 on consumer rights, and its EmpCo provisions apply from 27 September 2026.

What counts as an environmental claim on a website?

EmpCo uses a broad definition: an environmental claim is any message or representation, in text, images, graphics or symbols, that states or implies that a product, product category, brand or business has a positive or zero impact on the environment, is less damaging than alternatives or has improved its impact over time. Labels, brand names, company names and product names count too when they carry that message.

On a website, this reaches well beyond the Sustainability page. Think along the lines of:

• homepage headlines, banners and campaign landing pages;
• product descriptions, category pages and comparison tables;
• badges, icons, seals and packaging shown in product photos;
• delivery options and checkout copy;
• company and product names;
• blog articles that promote your products or services.

Which kinds of green communication does EmpCo treat differently?

If you want to start an internal audit of your website’s texts, I find it useful to separate green communication into three working categories before touching a single line of copy, because certification is the requirement in only one of the three:

1. Specific environmental claims. “The packaging contains 85% recycled fiber by weight” is a specific claim. It needs to be true, precise and supported by evidence you can show, but it carries no automatic certification requirement.
2. Sustainability labels. A badge such as “Planet Friendly Certified” is a sustainability label. It must come from public authority or rest on a certification scheme that meets the directive’s criteria.
3. Claims about future performance. “Net zero by 2030” is a future claim. It needs a detailed implementation plan and regular verification by an independent third-party expert.

Two further rules cut across these categories: the restriction on generic claims such as “eco-friendly”, and the prohibition on neutrality claims built on offsets. The next section covers both, together with the other practices worth reviewing first.

Which marketing practices should you review first?

Why are words like “eco-friendly” and “green” now a risk?

EmpCo prohibits generic environmental claims when the company cannot demonstrate it. The directive’s own examples include “environmentally friendly”, “eco-friendly”, “green”, “ecological”, “climate friendly”, “energy efficient”, “biodegradable” and “biobased”.

A claim counts as generic when the explanation of what it means is missing from the same place where the claim appears, stated clearly and prominently.

Compare “Eco-friendly packaging” with “The packaging contains 85% recycled fiber by weight.” The second sentence tells the customer exactly which environmental characteristic you are describing, and the first asks them to imagine a broad benefit.

Can one sustainable feature describe the whole product or the whole company?

The EmpCo Directive expressly prohibits businesses from making environmental claims about an entire product or business, when those claims are based solely on a single aspect of the product that is not representative of the business as a whole.

If only the box is recycled, say so: “The cardboard box contains 85% recycled fiber.” If renewable electricity covers one office, name it: “Our Bucharest office uses electricity from [specified source or contract].” Packaging is one part of the product, one office is one part of the company, and one initiative is one part of the business, and your copy should keep each fact attached to the part it describes.

Can carbon offsets still support a “carbon neutral” claim?

EmpCo prohibits claiming, based on offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive climate impact. The directive’s examples include “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero”, “climate compensated” and “reduced climate impact”. Under EU consumer law, a product includes services, so “carbon-neutral delivery” built on offsets falls under the same rule.

Your business can keep funding environmental projects and buying carbon credits, and you can tell customers about those investments in accurate terms. What changes is the conclusion you draw from them.

What happens to badges your team designed in-house?

Many websites display marks such as “Eco Choice”, “Green Standard” or “Responsible Product”, and some of them were created by a marketing team. From 27 September 2026, displaying a sustainability label that is neither established by a public authority nor based on a certification scheme is a prohibited practice in all circumstances.

A qualifying certification scheme relies on independent third-party verification that publishes its requirements, is open to all on transparent, fair and non-discriminatory terms, and has compliance monitored by a third party (whose competence and independence rest on international, EU or national standards). The Commission’s updated FAQs add two clarifications: the business owner and the verifier must be legally separate entities, and only public authorities of EU Member States count as public authorities for this rule.

When doing your internal website audit, start with an inventory of every environmental logo, icon, seal and badge on your site, and answer six questions for each one:

1. Who created it?
2. What exactly does it certify?
3. Is it a marketing graphic or a sustainability label?
4. Who verifies compliance, and are they independent from the scheme owner?
5. Are the scheme’s requirements public?
6. Does the scheme meet the EmpCo criteria?

Renaming a badge to “verified” or giving it a new color leaves its legal status exactly where it was, so the answers to these six questions are what decide whether it stays. On most of the websites I look at, this inventory takes an afternoon and ends with two or three graphics to retire, which is a small job once you know which ones they are.

What does a “net zero by 2030” claim need behind it?

Promises such as “Net zero by 2030”, “Climate positive by 2040” or “100% sustainable by 2035” can be potentially misleading when they lack clear objectives, publicly available and verifiable commitments and a realistic implementation plan. That plan needs measurable targets and an independent third-party expert must verify progress regularly, with the findings made available to consumers.

They usually apply to big businesses, but if you have something like it on your website, the working rule for your team is that a future environmental claim leaves the marketing department after the operational plan behind it exists, so your copy stays level with the business plan it describes.

Do durability and repair promises count too?

They do. EmpCo also covers claims about how long a product lasts, whether it can be repaired, how software updates affect it and when consumables need replacing. Falsely claiming that a good lasts a certain time or intensity of use under normal conditions becomes a prohibited practice, and so does presenting a good as repairable when it is not.

Phrases like “Built to last”, “Designed for years of use” and “Easy to repair” read like ordinary brand copy. When they describe a factual product characteristic, you need the evidence to stand behind them, or a rewrite that states the actual conditions.

What online shops need to display from 27 September 2026?

If your website offers services, the previous sections already cover what you need. If it sells products, EmpCo adds information that must appear on your pages and in your checkout, which makes this a job for your design and development team alongside copywriters. Most of it is template work that you plan once and reuse across the catalogue, so I would put it on the same list as any other seasonal update to the shop.

What is the harmonized notice, and where does it go on your site?

Every company selling goods to consumers must display a harmonized notice reminding them of the legal guarantee of conformity. For online sales, the directive describes it as a general reminder on the website, and in practice it belongs both in your site-wide layout and in your checkout.
Its design is fixed by Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025.

The text, visual elements, colors and the QR code or link to the European consumer portal are all prescribed, so you use the official file as published, without adapting its wording or restyling it to match your brand. The Commission provides the files for download in all official EU languages.

When do you need the GARAN label?

The same regulation introduces a second tool, which the legal texts call the harmonized label for the commercial guarantee of durability. “GARAN” is the title printed on the standardized graphic, a word that reads as “guarantee” in several EU languages.

The label applies when a producer offers a commercial guarantee of durability that meets three conditions: it comes at no additional cost, it covers the entire product and it lasts longer than two years. As a retailer, you display it when the producer makes that information available to you; the obligation starts from what the producer communicates.

The label is separate from the legal guarantee and sits alongside it. On a product page, the label allows a nested display but should be visible enough.

When must the label appear during checkout?

EmpCo amended Article 8(2) of the Consumer Rights Directive, the rule for online orders that create an obligation to pay. Under that article, key information must be brought to the customer’s attention clearly and prominently, directly before they place the order, and the durability guarantee information is part of it. 

The Commission’s practical guidelines confirm that the GARAN label should also appear on the checkout page, directly before the order is placed. A link to your Terms and Conditions page does not meet this requirement, because the information must be visible at the moment of decision.

What do you tell customers about software updates and repairs?

For goods with digital elements, and for digital content and digital services, you need to state the minimum period during which software updates will be provided, when the producer or provider has made that information available.

Where an EU reparability score exists for a product group, you show that score. Where it does not, and the producer provides repair information, that information becomes relevant: availability of spare parts, their estimated cost, how to order them, and the repair and maintenance instructions and restrictions.

What changes for your delivery options?

Where you offer environmentally friendly delivery options, the amended Consumer Rights Directive requires you to inform customers about them as part of your delivery information. Sustainability communication therefore extends into shipping settings and checkout design, and any environmental description of a delivery option follows the same claim rules described above.

How do you audit your website page by page?

Starting this type of audit on your business website or online shop can seem daunting, but it just takes a bit of coordination between your internal departments or freelance collaborators. When I go through a website for this, I work in one fixed order, because each step narrows the work for the next one.

I start with the general pages: homepage, About page and the Sustainability page, and I search for the broad words: sustainable, responsible, eco, environmentally friendly, planet positive, low impact and climate friendly. For every one of them I will need the exact environmental characteristics, otherwise they get removed.

Then I move to the product pages, where the useful move is to separate claims about the product itself from claims about its packaging, its manufacturing, its energy use, its transport, its recycled content and its recyclability. Keeping the evidence attached to its own level is what protects you here, so proof about the box supports statements about the box and nothing more.
Badges and icons come next, and the six questions above give you the inventory for every mark on the site.

If your website compares products on environmental, social or circularity aspects, the comparison pages need three things published alongside them: the method you compare by, the products and suppliers included, and the way you keep the information current. EU consumer law treats these as material information, meaning details a customer needs in order to decide, so they belong on the page rather than in an internal document.

The checkout deserves its own pass, with a look at the legal guarantee notice, the GARAN label where it applies, its placement directly before the order button, the delivery options and any environmental wording attached to them.

The blog and the campaign landing pages close the audit. When an article or a landing page promotes your products, its environmental claims follow the same rules as your product copy, and I have seen more forgotten green claims sitting in old campaign pages than anywhere else on a site.

How should green copy change? Before and after

Here are some examples of reframing green claims into more specific and substantiated statements:

1. General environmental claims
   • Before: “We are a 100% green company.”
   • Better direction: “Our Bucharest office purchased 100% renewable electricity in 2025 under [defined arrangement].”
   • Why: The revised wording defines the scope, subject, and relevant period of the claim.
2. Claims about packaging
   • Before: “Eco-friendly packaging.”
   • Better direction: “The cardboard packaging contains 85% recycled fiber by weight.”
   • Why: The revised wording replaces an undefined overall environmental benefit with a specific and measurable characteristic.
3. Claims based on one component of a product
   • Before: “Our product is sustainable because the box is recycled.”
   • Better direction: “The outer cardboard box contains X% recycled material.”
   • Why: The revised claim keeps the environmental characteristic attached to the specific part of the product to which it relates, rather than presenting it as a characteristic of the product as a whole.
4. Carbon-neutral delivery claims
   • Before: “Carbon-neutral delivery,” based on offsets.
   • Better direction: Explain the measured reduction in operational emissions separately and disclose any offset investments separately.
   • Why: Offsetting cannot be used as the basis for a product or service climate-neutrality claim.
5. Sustainability labels and badges
   • Before: “Green Choice” badge.
   • Better direction: Remove the badge unless it qualifies under the applicable sustainability-label rules.
   • Why: Sustainability labels must be based on a qualifying certification scheme or established by a public authority.
6. Future environmental performance claims
   • Before: “Net zero by 2030.”
   • Better direction: Use the claim only where the underlying plan, targets, resources, and independent verification satisfy the applicable requirements for future performance claims.
   • Why: Aspirational environmental claims require credible operational infrastructure and substantiation.
7. Repairability claims
   • Before: “Easy to repair.”
   • Better direction: State the actual repair conditions or provide specific information about the repair options available.
   • Why: Unsupported claims about repairability may be prohibited.

These examples show how environmental claims can be made more specific, transparent, and closely connected to the characteristics they describe. 

How do you keep claims accurate after publication?

EmpCo requires you to be able to back up what you say, and it leaves the format of your internal records to you. The most practical format I know is a Green Claims Evidence Map: one shared document where every environmental claim on your website has its own entry. This is good governance practice, and it means that when a customer, a journalist or an authority asks about a claim, the answer is already assembled.

For each claim, record the claim itself, its exact subject and scope, the evidence, the person responsible for that evidence, the date or period it covers, any verification and every page where the claim appears. For example:

• Claim: “Packaging contains 85% recycled fiber.”
• Subject: Outer cardboard box.
• Evidence: Supplier specification and procurement records.
• Period: Current packaging specification.
• Owner: Procurement.
• Website locations: Product page, sustainability page, campaign assets.

Then run a simple seven-step workflow:

1. Inventory every environmental claim on the site.
2. Classify each one: generic claim, specific claim, sustainability label, future claim, climate neutrality claim, or durability and repairability claim.
3. Define its scope precisely.
4. Verify the evidence before publication.
5. Rewrite the claim to match the evidence.
6. Map every approved claim to every page where it appears.
7. Review the map whenever suppliers, products, energy contracts or calculation methods change.

The last step keeps the whole system honest over time. A claim that was accurate on the day you published it can become misleading six months later if the product, the supplier or the packaging change, and the map tells you exactly which pages to update.

What does this mean for businesses in Romania?

OUG 18/2026 brings the EmpCo rules into Law no. 363/2007 and OUG no. 34/2014, and ANPC (the National Authority for Consumer Protection) is the authority that checks compliance and applies sanctions.

Under Law no. 363/2007, misleading commercial practices under Articles 6 and 7, as well as practices listed as misleading in Annex 1, are punishable by fines of RON 20,000 to RON 100,000. If an unfair commercial practice affects more than 100 consumers, both the minimum and maximum limits of the applicable fine are doubled. For widespread infringements and widespread infringements with a Union dimension, as defined by Regulation (EU) 2017/2394, the fine ranges from 0.1% to 4% of the trader’s annual turnover generated in Romania in the financial year preceding the sanction. Where that turnover information is unavailable, the law provides for a fine of between EUR 200,000 and EUR 2 million, payable in lei.

A green claim on your website is therefore a consumer protection matter with financial consequences, which is one more reason to treat the audit as a scheduled task. Treated that way, it stays a two-week project with a clear end, and the work you do once becomes the map you maintain from then on.

What is the one rule to remember?

EmpCo keeps sustainability communication open to every business that can show what it has done. The rule it sets is that a single word should never carry more environmental meaning than your evidence proves.

A strong environmental claim answers five questions: what changed, where, by how much, during what period and according to what evidence.

For businesses that are improving their products and operations, this is good news. Specific facts give you a way to show your work, and they give your customers a way to compare you with competitors on something concrete.

If you would like help mapping where these claims sit on your website and adjusting your product pages and checkout before the deadline, I can review them with you but don’t forget to loop in your legal advisers.