Generic environmental claims vs sustainability labels under EmpCo

Last review: 28 September 2026.

Directive (EU) 2024/825 (EmpCo) amends the Unfair Commercial Practices Directive (UCPD). As of 27 September 2026, Member States apply the new rules on environmental claims and sustainability labels. This guide contrasts generic environmental claims with private sustainability labels. It is not legal advice. Only the Official Journal text and Court of Justice case law are authoritative.

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Two different blacklisted practices

EmpCo adds two distinct entries to Annex I of Directive 2005/29/EC:

Point 2a covers sustainability labels that are not based on a certification scheme or not established by public authorities. A dedicated guide on this site explains point 2a and certification schemes.
Point 4a covers generic environmental claims for which the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.

Marketing teams and label owners should treat these as separate checks. A compliant sustainability label does not by itself justify vague wording such as "green" or "ecological" outside the label. Conversely, a specific factual claim on packaging is not a substitute for a certification scheme when you display a sustainability label.

What counts as a generic environmental claim

Article 2, point (p), of Directive (EU) 2024/825 defines a generic environmental claim as any environmental claim made in written or oral form, including through audiovisual media, that is not included on a sustainability label and where the specification of the claim is not provided in clear and prominent terms on the same medium.

Recital (9) gives examples that suggest excellent environmental performance, such as "environmentally friendly", "eco-friendly", "green", "ecological", "climate friendly" or similar wording. When the specification appears in clear and prominent terms on the same medium (for example the same pack or online product page), the claim is not generic under this definition.

Recognised excellent environmental performance

Article 2, point (s), defines recognised excellent environmental performance as environmental performance compliant with Regulation (EC) No 66/2010 (EU Ecolabel), with officially recognised national or regional EN ISO 14024 type I ecolabelling schemes in the Member States, or with top environmental performance under other applicable Union law.

Recital (10) stresses that the recognised performance must be relevant to the entire claim. A trader cannot rely on one characteristic if the generic wording covers the product as a whole.

Sustainability labels still need a scheme or public authority

Point 2a and point 4a work together. Traders who use a private sustainability label must rely on a certification scheme that meets Article 2, point (r), or on a label established by public authorities. Generic environmental claims on advertising or packaging remain subject to point 4a unless an exception applies.

Scheme owners document requirements, monitoring and certificates. Traders who display the label must ensure the scheme terms are public and that monitoring is carried out by a competent third party.

How Label Registry helps (without certifying)

Glint publishes Label Registry, software from Glint. It is not a certification body, does not certify or verify compliance, and does not provide legal advice.

Verified product features you can use today:

Publish scheme terms and a frozen version on a public scheme page.
Run applications with legally separate verifier organisations.
Issue numbered certificates and list them on the public registry with QR verification links.
Run the EmpCo check (Diagnostic EmpCo) against Article 2, point (r).

Read the sustainability label guide Run the EmpCo check

EmpCo transposition tracker (EU 27)

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