# EmpCo: How the New EU Directive Impacts Nature Projects Last updated: 2026-11-01 > EmpCo bans telling EU consumers that offsets make a product climate neutral. What buyers can still say about nature projects, and the evidence they need. Date: November 1, 2026 EmpCo, Directive (EU) 2024/825, is the EU law behind national rules that member states had to apply from 27 September 2026. It bans telling consumers that a product is climate neutral, or has a reduced or positive climate impact, because of offsets. It also bans vague claims such as "eco-friendly" without recognised excellent environmental performance, and sustainability labels with no certification scheme or public authority behind them. It doesn't ban buying credits or funding nature projects: companies can still say specifically what they fund, if they can prove it. For developers, the value moves from a neutrality badge to evidence. [Restoration Scope](https://restorationscope.com/about), which makes field and monitoring software for nature projects, publishes this guide for restoration, reforestation and carbon project developers, and for the companies that fund them or buy their credits. For the carbon standards themselves, see [carbon standards for nature projects](https://restorationscope.com/blog/carbon-standards-for-nature-projects). **Checked November 1, 2026:** against the [text of the directive](https://eur-lex.europa.eu/eli/dir/2024/825/oj), the [Unfair Commercial Practices Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02005L0029-20260927) it amends, the Commission services' [Questions & Answers](https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_en?filename=Q%26A%20ECGT_Directive_Sept%202026.pdf) (September 2026), the consumer authorities' [common understanding on old stock](https://commission.europa.eu/document/264d8c70-2f9a-4955-8e7b-154d55a9b684_en) (June 2026), the [national measures listed on EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/NIM/?uri=CELEX:32024L0825) and the European Parliament's [Legislative Train](https://www.europarl.europa.eu/legislative-train/theme-a-new-plan-for-europe-s-sustainable-prosperity-and-competitiveness/file-substantiating-green-claims). The Q&A is the Commission services' preliminary view, not a binding interpretation; national authorities and courts decide cases. This guide is a plain-language summary, not legal advice. ## What is the EmpCo Directive? EmpCo ("Empowering Consumers for the Green Transition", also called ECGT) is an EU directive of 28 February 2024 that amends two consumer laws: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). It entered into force on 26 March 2024 (Article 5); member states had to adopt and publish national laws by 27 March 2026 and apply them from 27 September 2026 (Article 4). It regulates what businesses tell consumers, on packaging, in adverts, on websites and through brand names. It doesn't regulate carbon credits, standards or projects. Five changes matter for nature claims: **[Directive 2005/29/EC](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02005L0029-20260927): provisions that matter for nature claims** - **Offset-based product claims** ([Annex I, point 4c](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024L0825#anx_1:~:text=4c.-,Claiming%2C%20based%20on%20the%20offsetting); banned outright): Saying a product has a neutral, reduced or positive greenhouse gas impact because of offsetting. - **Generic claims** ([Annex I, point 4a](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024L0825#anx_1:~:text=Making%20a%20generic%20environmental%20claim%20for%20which%20the%20trader%20is%20not%20able); banned outright): A vague environmental claim, such as “eco-friendly” or “climate friendly”, that the trader can’t back with recognised excellent environmental performance. - **Whole-business claims from one activity** ([Annex I, point 4b](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024L0825#anx_1:~:text=4b.-,Making%20an%20environmental%20claim%20about%20the%20entire%20product); banned outright): A claim about the entire product or business when it only concerns one aspect or activity. - **Labels without a scheme** ([Annex I, point 2a](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024L0825#anx_1:~:text=2a.-,Displaying%20a%20sustainability%20label%20that%20is%20not%20based); banned outright): Showing a sustainability label that isn’t based on a certification scheme or set up by a public authority. - **Future claims without a plan** ([Article 6(2)(d)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024L0825#art_1:~:text=(d)-,making%20an%20environmental%20claim%20related%20to%20future%20environmental%20performance); judged case by case): A claim about future performance, such as “net zero by 2040”, without a detailed, realistic plan verified regularly by an independent expert. The first four are on the blacklist in the UCPD's Annex I: banned in all circumstances, with no need to show that a consumer was misled. The fifth is judged case by case. "Recognised excellent environmental performance" has a narrow meaning: the EU Ecolabel, an officially recognised national or regional EN ISO 14024 type I ecolabel, or top performance under other EU law. It also has to be relevant to the claim. Without that, a claim has to be specified "in clear and prominent terms on the same medium" (in practice, the Q&A says, next to or as part of the claim), or not made. A specified claim still has to pass the other rules against misleading claims. Recital 10 adds that "conscious", "sustainable" or "responsible" shouldn't rest on recognised excellent environmental performance alone, because those words also cover social characteristics. ## Which claims about nature projects are now banned? Recital 12 lists examples of offset-based claims the ban covers: "climate neutral", "CO2 neutral certified", "carbon positive", "climate net zero", "climate compensated", "reduced climate impact" and "limited CO2 footprint". The Commission's Q&A gives a nature example: a flight called climate neutral because the airline invests in a tropical reforestation project. - “This coffee is climate neutral: we offset it by restoring forest in Peru.” On a pack. Banned outright: offset-based product claims (Annex I, point 4c). - “Carbon-neutral delivery” At checkout, backed by credits; a service counts as a product. Banned outright: offset-based product claims (Annex I, point 4c). - “Good for the planet” In an ad, or “nature positive”, with nothing next to it saying how, and no recognised ecolabel behind it. Banned outright: generic claims (Annex I, point 4a). - “We’re a regenerative company” On the About page, because one product line funds a restoration project, and nothing else in the business does. Banned outright: whole-business claims from one activity (Annex I, point 4b). - “Forest Friend” On a badge, the brand’s own seal, which shoppers read as an eco label, with no certification scheme behind it. Banned outright: labels without a scheme (Annex I, point 2a). - “Climate positive by 2030” In a pledge, with no published, verified plan. Judged case by case: future claims without a plan (Article 6(2)(d)). Images count too. The Q&A, quoting the Commission's 2021 guidance, says trees, rainforests, water, animals and green or blue colours can be implicit environmental claims. A picture alone isn't a generic claim, but a picture of a forest next to the word "sustainable" can be. Names can be claims as well. The definition of an environmental claim includes "brand names, company names or product names", and the Q&A says a name counts when it conveys an environmental message, explicitly or implicitly. ## Can companies still say they fund a reforestation or carbon project? Yes. Recital 12 says the offset ban "should not prevent companies from advertising their investments in environmental initiatives, including carbon credit projects, as long as they provide such information in a way that is not misleading and that complies with the requirements laid down in Union law". The Commission's Q&A (question 10) says the same, and adds that the point 4c ban doesn't apply to offset claims at company level, which still fall under the directive's other rules. That doesn't make a company "climate neutral" claim safe: the Q&A says generic claims such as "climate neutral" or "carbon positive" are banned under point 4a unless the trader can show recognised excellent environmental performance relevant to the claim. This is sometimes called a contribution claim: the company says what it paid for, not that the payment cancels its footprint. The directive doesn't use the term, and it doesn't give a template. What it does give is a test: a specific claim that the trader can back with evidence, that doesn't overstate the benefit or pass off one activity as the whole business. - Weaker: “Climate neutral thanks to our forest project” Stronger: “Since 2024 we have funded the restoration of [X] hectares of degraded pasture in [region], with [partner]. See the project’s latest monitoring report.” - Weaker: “We plant a tree with every order” Stronger: “For every order we fund one native tree planted by [partner] in [region]. [X] planted so far; [Y]% alive at the last survival count, [month year].” - Weaker: “Carbon positive brand” Stronger: “We bought and retired [X] tonnes of verified removal credits from [project] in [year]. They don’t reduce our own emissions, which are [X] tonnes.” The stronger versions say what was funded and add the details a reader needs to check it: where, how much, since when, and where to look. Most of those details come from the project. **Where each part of a contribution claim comes from** (example claim, made-up numbers): > For every order, we fund native trees on 35 hectares of former pasture in Bahia, Brazil: 41,200 planted since March 2024, 86% alive at the last survival check, in May 2026. See the live project map. 1. "on 35 hectares of former pasture in Bahia, Brazil": **Site boundaries**. The mapped area of each site the buyer funded. 2. "41,200 planted since March 2024": **Planting records**. Species, count and date for every planting. 3. "86% alive at the last survival check, in May 2026": **Survival checks**. Plots counted on a known date, so the claim doesn’t run ahead of the trees. 4. "See the live project map.": **Public project page**. Current maps and photos that carry their place and date, open to anyone. ## What about removals inside a buyer's own supply chain? Recital 12 says the ban targets offsetting "outside the product's value chain"; point 4c itself has no value-chain wording. The Commission's Q&A says a neutral, reduced or positive claim is not caught when it rests on the actual emissions footprint of the product across its value chain, and that such claims "would need to be substantiated through proper life cycle assessments". So agroforestry or restoration on the farms that supply a product, often called insetting, may support a claim about that product where an assessment shows a real, verifiable effect within the product's life cycle. The label "insetting" proves nothing by itself: what counts is the measured effect within the product's life cycle, not buying or retiring a credit, and the directive's other rules still apply. Either way, it raises the bar for farm-level records: which farms, which practices, from when, with what measured result. ## Does EmpCo apply to project developers? Mostly indirectly. The Commission's Q&A says the directive is "strictly limited" to business-to-consumer practices; business-to-business claims are outside it, though some fall under other EU rules, notably the Misleading and Comparative Advertising Directive, and member states may extend protection to businesses nationally. Annual sustainability reports are usually outside it too, unless their content is reused in consumer advertising. **Where EmpCo applies between a nature project and a consumer:** 1. **Project developer** (business to business: outside EmpCo). Outside, unless it sells to consumers. Restores the land and keeps the records: boundaries, plantings, survival counts, credits. 2. **Company that funds or buys** (to consumers: EmpCo applies). Its claims to consumers are covered. Funds the project or retires its credits, then tells consumers. Has to be able to prove what it says. 3. **Consumer** (to consumers: EmpCo applies). Protected by EmpCo. Reads the claim on a pack, an advert or a website. Three cases bring a developer in: - **You sell to consumers.** Tree sponsorships, gift trees, credits for individuals or a "plant a tree" checkout add-on are consumer sales, and your claims about them are covered. - **You give buyers a badge.** A logo or seal your buyers put on products or websites can be a "sustainability label", "any voluntary trust mark, quality mark or equivalent", when consumers read it as a mark of environmental quality. The Q&A says that depends on its use, context and consumer perception. If it is one, it can only be shown when based on a certification scheme: public requirements and terms, open on transparent, fair terms to all traders willing and able to comply, developed with experts and stakeholders, rules for non-compliance that can withdraw or suspend the label, and monitoring by a third party whose competence and independence from both the scheme owner and the trader rest on international, EU or national standards. The Q&A adds that the owner and the monitor must be separate legal entities. - **Your buyers' claims fail.** A buyer whose consumer claim relies on your numbers needs to be able to prove them. Under the Unfair Commercial Practices Directive, traders should be able to furnish evidence of the accuracy of factual claims (Article 12, as the Q&A notes). That burden lands on the buyer, and many buyers will pass it down. The Q&A also says labels set up by public authorities outside the EU don't count as "established by public authorities"; they need a certification scheme behind them to be shown in the EU. ## What evidence will buyers ask project developers for? The directive sets no evidence list for projects. But a buyer that wants to say anything specific about its support will need facts it can repeat and defend. Expect requests for: - **What was funded.** The activity, the area in hectares and its boundaries, the location, and the period. - **What happened on the ground.** Planting dates, species, numbers, maintenance and replanting, with the dates of each. - **What is still there.** Survival counts and their date, so a claim doesn't run ahead of the trees. - **Proof a stranger can check.** Photos with location and date, maps of the sites, and a public page or report a consumer can be sent to. - **Credit records, where credits are involved.** The standard, the project ID, the vintage and the retirement record in the registry, kept separate from the buyer's own emissions. - **Who checked it.** Validation, verification or certification status, and when it was last done. Keep it current: a dated claim ("planted in 2025") can stand, but a claim about now ("2,000 trees growing") needs current numbers. Projects that can hand this over quickly, for the exact sites a buyer funded, make their buyers' claims easier to keep. For the records funders ask for in general, see [restoration monitoring for funders](https://restorationscope.com/blog/restoration-monitoring-system-funders) and [how to track tree planting survival](https://restorationscope.com/blog/track-tree-planting-survival). ## Where does field monitoring data fit? Most claims about nature projects that survive EmpCo will be specific, and a specific claim about what happened on the ground ends in a field record: a boundary, a planting date, a survival count, a photo with a location. When those records are scattered across spreadsheets and phones, buyers get round numbers and old reports, and their claims get vaguer or riskier. Restoration Scope keeps those records connected for each site. Teams map boundaries or walk them with GPS, record planting and survival checks offline, and attach photos that carry their location. Tables export as CSV and sites as GeoJSON, and we set up public portals where funders and consumers read the latest record without signing in. It doesn't verify projects, certify claims, run life cycle assessments or issue credits, and it isn't legal advice: buyers still need their own review of what they say. See [Restoration Scope for carbon projects](https://restorationscope.com/solutions/carbon). ## What about net-zero and other future claims? Claims about future environmental performance, at product or company level, can be misleading when they don't rest on "clear, objective, publicly available and verifiable commitments" in a "detailed and realistic implementation plan" with measurable, time-bound targets and resources, "regularly verified by an independent third party expert" whose findings are available to consumers (Article 6(2)(d)). Like the other Article 6 rules, it is judged case by case, by whether it is likely to make the average consumer take a transactional decision they wouldn't otherwise take. The Q&A says the directive doesn't fix how often verification happens and suggests yearly or two-yearly reviews, or more after significant changes. Consumers must be able to reach both the plan and the findings easily; a QR code is one way. ## How does EmpCo relate to the Green Claims Directive? The Green Claims Directive is a separate, stalled proposal that would set detailed rules for substantiating and verifying environmental claims before they're made. It is not law. Its status, from the European Parliament's [Legislative Train](https://www.europarl.europa.eu/legislative-train/theme-a-new-plan-for-europe-s-sustainable-prosperity-and-competitiveness/file-substantiating-green-claims): - **22 March 2023:** The Commission proposes it, COM(2023) 166. - **12 March 2024:** Parliament adopts its first-reading position. - **17 June 2024:** The Council adopts its general approach. - **28 January and 24 April 2025:** First and second trilogues. - **20 June 2025:** The Commission announces that it intends to withdraw the proposal. - **23 June 2025:** The third trilogue is cancelled. - **21 October 2025:** The 2026 Commission work programme lists the proposal as pending. - **20 September 2026:** Latest Legislative Train update: status "Blocked", by the Council. EmpCo sets the bans; the Green Claims Directive would set how to prove what's left. With it stalled, the blacklist applies as written, and everything else is judged case by case under the amended consumer rules by national authorities and courts. ## Has every EU country transposed EmpCo, and who enforces it? The record isn't complete. As of 1 November 2026, [EUR-Lex lists](https://eur-lex.europa.eu/legal-content/EN/NIM/?uri=CELEX:32024L0825) national measures notified by 22 of the 27 member states, and none for Spain, Malta, Portugal, Slovenia or Sweden. A notified measure isn't proof of complete transposition, and a missing one isn't proof of none. On 28 May 2026 the Commission sent [letters of formal notice](https://ec.europa.eu/commission/presscorner/detail/en/inf_26_1097) to 20 member states for not communicating complete transposition, including the Netherlands and Austria, which have both notified measures since. No measure listed: Spain, Malta, Portugal, Slovenia, Sweden Examples of national laws: - **Germany:** the Third Act amending the Act against Unfair Competition (UWG), published 19 February 2026. - **Italy:** Legislative Decree of 20 February 2026, No. 30. - **Netherlands:** the Act of 27 May 2026 implementing the directive. - **Ireland:** the European Union (Empowering Consumers for the Green Transition) Regulations 2026. - **Austria:** amendments to its Unfair Competition Act and consumer law, published 28 July 2026. The existing rules against misleading claims already apply everywhere; the Commission's Q&A notes that they could be used against greenwashing before EmpCo applied. **Who enforces.** National consumer authorities and courts. Under some national laws, people and organisations can also bring cases, as the Q&A notes; in Germany, for example, competitors, trade associations and consumer associations can sue under [section 8(3) of the UWG](https://www.gesetze-im-internet.de/uwg_2004/__8.html). Penalties are set nationally. For penalties imposed in coordinated actions under Article 21 of the Consumer Protection Cooperation (CPC) Regulation, national law must allow maximum fines of at least 4% of the trader's annual turnover in the member states concerned, or at least EUR 2 million when turnover data isn't available (UCPD Article 13, as amended by [Directive 2019/2161](https://eur-lex.europa.eu/eli/dir/2019/2161/oj)). **Old stock.** The rules apply to products and packaging already made or on shelves. In June 2026 the CPC network published a common understanding: authorities may phase enforcement where old stock causes genuine and specific difficulty, may favour corrections such as stickers or updated online claims, and may avoid requiring destruction or recall. It isn't a formal CPC position or a binding interpretation, and it doesn't stop action in a specific case. Online claims and adverts are expected to change right away. More guides: [carbon standards for nature projects compared](https://restorationscope.com/blog/carbon-standards-for-nature-projects), [Plan Vivo vs Gold Standard vs Verra](https://restorationscope.com/blog/plan-vivo-vs-gold-standard-vs-verra) and [restoration monitoring for funders](https://restorationscope.com/blog/restoration-monitoring-system-funders). **Disclosure:** Restoration Scope makes field and monitoring software for restoration and carbon project developers. We are not a standard, a registry, a verifier or a law firm, and we don't sell credits. ## Questions about EmpCo and nature projects ### What is the EmpCo Directive? [Directive (EU) 2024/825](https://eur-lex.europa.eu/eli/dir/2024/825/oj) on empowering consumers for the green transition. It amends the Unfair Commercial Practices Directive to ban generic environmental claims the trader can't back with recognised excellent environmental performance, offset-based claims that a product is climate neutral or has a reduced or positive climate impact, and sustainability labels without a certification scheme or public authority behind them. Future claims without a verified plan can also be misleading, judged case by case. It covers what businesses tell consumers in the EU. ### When does EmpCo apply? The directive entered into force on 26 March 2024. Member states had to adopt national laws by 27 March 2026 and apply them from 27 September 2026. Not all have: as of 1 November 2026, EUR-Lex lists no national measure for five of them, and on 28 May 2026 the Commission sent 20 member states [letters of formal notice](https://ec.europa.eu/commission/presscorner/detail/en/inf_26_1097) for not communicating complete transposition; several have notified measures since. There is no transition period for claims or labels already on the market. In June 2026 national consumer authorities published a common understanding: they may phase enforcement where old stock causes genuine and specific difficulty; it isn't a binding position, and old stock doesn't exempt traders from the rules. ### Can a company still call a product carbon neutral? Not on the strength of offsets. Point 4c of Annex I to the Unfair Commercial Practices Directive, added by EmpCo, bans claiming, based on offsetting, that a product has a neutral, reduced or positive impact in terms of greenhouse gas emissions. Recital 12 says such a claim should only be allowed when it rests on the product's actual life cycle impact, not on offsetting outside its value chain; the Commission's Q&A says it would need a proper life cycle assessment. The Commission's Q&A says a claim such as "reduced CO2 impact" based on real improvements in production can be made if it is specified in clear and prominent terms on the same medium; other rules still apply. ### Can companies still buy carbon credits or fund reforestation? Yes. Recital 12 says the ban should not stop companies advertising their investments in environmental initiatives, including carbon credit projects, as long as the information is not misleading and complies with EU law. The Commission's Q&A repeats this. What changes is the wording: say what was funded, not that it cancels a product's footprint. A generic "climate neutral" or "carbon positive" claim about the company is still banned under point 4a unless the trader can show recognised excellent environmental performance relevant to the claim. Spelling it out takes it out of point 4a, but it still has to be accurate and not misleading, and it is still judged case by case under the other rules against misleading claims. ### What evidence will buyers ask nature project developers for? The directive sets no list for projects, but a buyer that makes a specific claim about its support has to be able to back it. Expect requests for what was funded (activity, hectares, boundaries, location, period), what happened on the ground (planting dates, species, numbers, maintenance), what is still there (dated survival counts), proof a stranger can check (located, dated photos, maps, a public page), credit records where credits are involved, and who verified it and when. ### Does EmpCo apply to business-to-business claims? No. The Commission's Q&A says the directive is strictly limited to business-to-consumer practices. Some business-to-business practices fall under other EU rules, notably the Misleading and Comparative Advertising Directive, and member states may extend protection to businesses nationally. A project developer selling credits to a company is outside it; the company's claims to consumers are inside it, and so is a developer that sells to consumers directly. ### Has the Green Claims Directive been withdrawn? Not formally. The Commission announced on 20 June 2025 that it intends to withdraw the proposal, and the trilogue set for 23 June 2025 was cancelled. The 2026 Commission work programme lists it as pending, and the European Parliament's Legislative Train shows it as blocked by the Council (updated 20 September 2026). It is not law. ### Does the evidence behind a claim have to be public, and who checks it? Under EmpCo, mostly not. No one approves claims in advance: national consumer authorities and courts enforce afterwards, and under some national laws competitors and associations can bring cases. They can require the trader to prove a factual claim, and treat it as inaccurate if the proof is missing or not enough ([UCPD](https://eur-lex.europa.eu/eli/dir/2005/29/oj) Article 12). What consumers must be able to see: what a written or spoken environmental claim means, specified on the same medium, or it counts as generic; for a sustainability label, a certification scheme with public terms and independent monitoring, or a public authority behind it; and for a future claim, the public commitments and the independent expert's findings, which a QR code can point to. The directive doesn't require the project file itself to be published. ### What are the penalties for breaking EmpCo? Each member state sets them. In coordinated EU enforcement actions under the Consumer Protection Cooperation Regulation, national law must allow maximum fines of at least 4% of the trader's annual turnover in the member states concerned, or at least EUR 2 million when turnover data isn't available ([Directive 2019/2161](https://eur-lex.europa.eu/eli/dir/2019/2161/oj), Article 3).