EmpCo Compliance: 20 Checkpoints for Your Online Shop

From 27 September 2026, EU Directive 2024/825 (EmpCo) will tighten the rules for environmental claims in both B2B and B2C contexts. Online shops are particularly affected, as they disseminate a wide range of product information and marketing messages. Early review and adaptation are essential to avoid fines and damage to reputation.

Checkpoints for Product Detail Pages

The product detail page is the central location for information and therefore also the main area where violations of EmpCo can occur.

1. **Product Title:** Avoid generic environmental terms such as “sustainable” or “environmentally friendly” without concrete evidence. 2. **Main Description:** Ensure that all environmental claims are substantiated by recognised certifications (e.g. EU-Bio, GOTS) or measurable data. 3. **Material Information:** When using mixed materials, specify the percentage of each material. This creates transparency and enables informed assessment. 4. **Certificate Logos:** Link certificate logos directly to the corresponding certification bodies and ensure that the certificates are current and valid. For example, a product with EU-Bio certification should have a link to the official EU-Bio database. 5. **Detailed Product Information:** Create separate tabs for care instructions, origin information and sustainability aspects to ensure comprehensive information.

Filters and Categories: Creating Transparency

Filters and categories allow customers to search for products based on specific criteria. It is important to define clear and comprehensible criteria here.

6. **“Sustainable” Filter:** Define clear criteria for the use of the “Sustainable” filter. This could include, for example, compliance with certain environmental standards or the use of recycled materials. 7. **“Bio” Filter:** Use the “Bio” filter exclusively for products that have been awarded a recognised organic certificate (e.g. EU-Bio, Demeter). 8. **“Recycled” Filter:** Only use the “Recycled” filter for products that demonstrably contain a high proportion of recycled material (>50%).

Shipping and Packaging: Making Concrete Information Available

Clear and transparent information is also required in the area of shipping and packaging.

9. **Shipping Options:** Avoid statements such as “carbon neutral shipping” without a transparent methodology for calculating and offsetting CO2 emissions. 10. **Packaging Materials:** Provide concrete information about the packaging materials used, including the proportion of recycled material and disposal instructions.

Newsletter and Marketing: Pay Attention to Formulations

You must also comply with the EmpCo Directive in newsletters and marketing materials.

11. **Newsletter Subject Lines:** Avoid generic environmental terms in newsletter subject lines. 12. **Own “Eco” Labels:** Do not use in-house “Eco” labels without an external, independent certification system. 13. **Footer Disclaimer:** Update the disclaimer in the newsletter footer with a note on compliance with the EmpCo Directive.

Legal Aspects: Check Terms and Conditions and Imprint

14. **Terms and Conditions:** Include a clause in the terms and conditions excluding greenwashing statements by the provider. 15. **Imprint FAQ:** Update the FAQ in the imprint with information on your company’s EmpCo status.

Common Weaknesses: Often Overlooked

16. **Alt Texts of Product Images:** Check the alt texts of product images for misleading environmental claims. 17. **PDF Product Data Sheets:** Ensure that PDF product data sheets also comply with EmpCo requirements. 18. **Schema.org Markup:** Check the Schema.org markup for the use of terms such as “sustainable”. 19. **Multilingual Versions:** Ensure that all multilingual versions of your website are checked and adapted in sync.

Consider Judgments and Certificates

20. **Current Case Law:** Note current case law, in particular the judgment of the German Federal Court of Justice (BGH (I ZR 98/23), German Federal Court of Justice) on carbon neutral claims. Use recognised certificates such as EU-Bio, GOTS or OEKO-TEX 100 to substantiate your environmental claims.

By implementing these 20 checkpoints, you can ensure that your online shop complies with the requirements of the EmpCo Directive from 27 September 2026 and thus operates legally and in a trustworthy manner. Proactive adaptation is not only legally necessary, but also strengthens your company’s image and your customers’ trust.