Most coverage of the EmpCo Directive lists what disappears on 27 September 2026. That is the shorter list. Three categories of environmental claim remain fully usable, and they happen to be the three that were always more persuasive than the ones being removed.
Here is what each requires.
1. The specific single-aspect claim
What it looks like: "This bottle is made from 100% recycled PET." "Our Rotterdam site runs on contracted Dutch wind power." "This packaging is recyclable in Dutch kerbside collection."
Why it survives: The Directive bans generic claims, which it defines as environmental claims made without demonstrating recognised excellent environmental performance relevant to the claim. A claim about one named attribute, with the attribute quantified, is the opposite of generic.
What it requires: Evidence for the specific attribute, and precision about scope. "Recyclable" needs a stated system, because a material recyclable in one country's infrastructure may not be in another's. "Recycled content" needs a percentage and a boundary: the bottle, or the bottle and the cap and the label.
The common failure here is quiet scope inflation. A claim true of one component gets applied to the whole product. That was always misleading; it is now a prohibited practice.
2. The verified reduction claim
What it looks like: "We cut Scope 1 and 2 emissions 41% between 2021 and 2025." "The footprint of this product fell 28% after we changed the resin supplier."
Why it survives: It describes something that happened, which you can evidence. It makes no claim of neutrality and does not depend on offsetting.
What it requires: A baseline and a current figure, calculated on the same boundary with the same method. This sounds obvious and is where most reduction claims fall apart.
Three things break a reduction claim under scrutiny:
- The boundary moved. You added Scope 3 categories, or divested a site, and the two years are no longer comparable. Recalculate the baseline whenever the boundary changes, and say that you did.
- The method changed. Switching emission factor databases mid-series can produce a "reduction" that is entirely an artefact of the factors.
- The reduction is intensity, not absolute. Emissions per unit falling while total emissions rise is a legitimate thing to report, but it must be labelled as intensity. Presenting intensity as absolute reduction is exactly the kind of misleading omission the Directive targets.
Get these right and the reduction claim is stronger than the neutrality claim it replaces, because it survives being checked.
3. The certified label
What it looks like: An EPD registered in the Nationale Milieudatabase. A Cradle to Cradle certification. An ISO 14001 certificate. A product footprint verified to ISO 14067.
Why it survives: The Directive explicitly protects sustainability labels based on certification schemes that are independent, transparent, and credibly governed. What it removes is the self-declared label, particularly the brand-invented badge that resembles a certification without any third party behind it.
What it requires: That the scheme is genuinely independent, and that you represent what it covers accurately. An EPD covers the declared product on a declared functional unit. It does not make your company sustainable, and stretching it that way turns a solid asset into a misleading claim.
The pattern underneath all three
Each permitted claim has the same shape: a named aspect, a number, a method, and evidence available on request.
That is a higher bar than "carbon neutral" ever was, and it is also more useful commercially. Procurement teams, tender evaluators and corporate customers running supplier questionnaires were never persuaded by neutrality claims. They ask for the underlying data. A company that has moved to specific evidenced claims is already answering the question its buyers were asking.
What this means practically
The businesses that will struggle in September are the ones whose sustainability story is entirely narrative, with no measurement underneath. The businesses that will barely notice are the ones already calculating footprints, because they can swap claim wording in an afternoon.
If you are between those two positions, the sequence is: measure first, then write the claim to fit the evidence. Claims written before the measurement almost always overreach.
A product carbon footprint or LCA gives you the product-level numbers. A corporate footprint covers organisational claims. For construction products, an EPD does both jobs at once: it is a certified label and the data source for specific claims.
For reduction claims, the requirement is continuity rather than a one-off calculation. Keeping the baseline and every subsequent year on one consistent method is what makes the claim defensible three years from now, which is the argument for a carbon platform over a spreadsheet rebuilt annually.
Start with what you already have
Most companies hold more evidence than their marketing uses. Footprint calculations sit in finance, EPDs sit with the technical team, and the website still says "eco-friendly" because nobody connected the two.
Auditing that gap is usually the fastest route to a compliant and more convincing set of claims. Read the full breakdown of what the Directive prohibits, or talk to us about a claim audit.
Sources: Directive (EU) 2024/825, EN 15804+A2, ISO 14067.
