Complaints and appeals for an EmpCo certification scheme

Last review: 29 September 2026.

Article 2, point (r), of Directive (EU) 2024/825 requires a certification scheme to set out procedures for non-compliance. Good practice is to publish how anyone can raise a concern, how the scheme owner responds within stated deadlines, and how an appeal is handled separately from the original decision-maker. This guide summarises those expectations. It is not legal advice. Only the Official Journal text and Court of Justice case law are authoritative.

Sources:

• Directive (EU) 2024/825 on EUR-Lex (CELEX:32024L0825)
• Directive 2005/29/EC on EUR-Lex (CELEX:32005L0029)

Non-compliance procedures in the scheme terms

A certification scheme must describe what happens when a certified trader does not meet published requirements. That includes suspension or withdrawal of the right to use the sustainability label when justified. The procedures should be public, predictable and applied consistently.

Stakeholders and buyers need to know where to report suspected misuse of the label or weaknesses in how the scheme is run.

Complaints channel and response deadlines

Scheme owners typically publish:

• Who may file a complaint (for example certificate holders, competitors, consumers or NGOs).
• What information the complaint must include.
• Acknowledgement and review timelines.
• How outcomes are communicated, including any public note linked to the certificate when a status changes.

Glint publishes Label Registry so scheme owners can document these rules on the public scheme page and collect complaints online. Glint is the publisher of the software. It is not a certification body and does not handle complaints on behalf of scheme owners.

Appeals distinct from the decision-maker

When a trader challenges a certification decision, the appeal should be reviewed by someone who was not involved in the original decision, within published deadlines. The appeal path should be described next to the complaint process so readers see two separate routes.

What you can use on Label Registry today

On each published scheme page you will find **Complaints** and **Appeals** sections when the owner has filled them in. Anyone can file a complaint for the demo scheme:

Scheme owners signed in to Label Registry can track complaints and appeals in the workspace.

EmpCo transposition tracker (EU 27)

Operational aid. This page is not legal advice, and Glint does not certify.