EmpCo Quick Check
Where are the EmpCo risks in your sustainability communication?
The Empowering Consumers Directive (EmpCo) will prohibit many common sustainability claims from September 2026. With our AI-powered Quick Check, we identify potential conflict cases in your communication—quickly, systematically, and with concrete recommendations for action.
27.09.2026
Deadline for mandatory application in Germany
EmpCo applies to all companies that advertise to or sell to consumers in the EU
Non-EU providers are also affected; only purely B2B communication is exempt
No transitional periods are предусмотрены
No need to worry—we will prepare you: Book a free initial consultation.
Dr. Martin Granzow
Managing Director Founder | Nextra Consulting
Background
What is EmpCo?
The Empowering Consumers for the Green Transition Directive (EU) 2024/825 is the “sister directive” of the Green Claims Directive. Its goal: to stop greenwashing and empower consumers to make more sustainable purchasing decisions through better information.
In Germany, the directive will expand the Act Against Unfair Competition (UWG) to include specific greenwashing prohibitions. It affects websites, online shops, packaging, press releases, annual reports, and other public communication channels.
EmpCo clearly defines which types of sustainability claims will be prohibited in the future—thereby establishing a clear regulatory framework for corporate communications.
Timeline
February 2024
Adoption of the EmpCo Directive (EU) 2024/825
March 2024
Publication and entry into force at EU level
By March 2026
Member States must enact and publish implementation in national law
From September 27, 2026
Mandatory application in Germany: UWG expanded to include greenwashing prohibitions
Regulatory framework
These practices are prohibited under EmpCo
The directive addresses 7 key categories of unfair sustainability claims that are widespread in corporate communications.
Generic environmental claims
Vague terms such as “environmentally friendly,” “climate-friendly,” or “sustainable” without substantiated evidence
Incomplete environmental claims
Claims that highlight only partial aspects and omit relevant limitations
Irrelevant benefits
Highlighting environmental characteristics that do not differentiate within the product category
Legal requirements presented as a special feature
Presenting legally required standards as a voluntary sustainability achievement
Climate neutrality through offsetting
Claims such as “CO₂-neutral” or “climate-neutral” that are based exclusively on offsetting
Sustainability seals and labels
Use of non-certified seals or labels without completed third-party verification
Early obsolescence and repairability
Concealing planned obsolescence or misleading information about durability and repairability
Risks
Consequences of non-compliance
Companies risk significant sanctions—legal, financial, and reputational.
Cease-and-desist actions fines
Actors such as the Wettbewerbszentrale and Deutsche Umwelthilfe can bring cease-and-desist actions. EU Member States impose fines of up to 4% of annual turnover.
Reputational risk
Public condemnations have long-lasting effects. Consumers and investors lose trust—ESG ratings and financing terms deteriorate.
Advertising ban product withdrawal
Courts order the immediate cessation of all affected communication materials—website, packaging, advertising, investor relations.
Access to capital markets
Investors and banks increasingly demand verifiable ESG data. Inaccurate green claims jeopardise credit lines, green bond issuances, and ESG ratings.
Our approach
The EmpCo Quick Check with an AI agent
Our EmpCo Quick Check combines the efficiency of a specialized AI agent with the expert assessment of experienced sustainability consultants. The Nextra EmpCo AI agent systematically screens your public sustainability communication for potential conflict cases—across websites, online shops, press releases, annual reports, and other touchpoints. The identified claims are then professionally evaluated by our consultants, prioritized by risk indication, and provided with concrete mitigation proposals.
Process
How the Quick Check works
In five structured steps, from source selection to a handover-ready result:
Joint definition of the sustainability touchpoints to be reviewed: website, shop, press releases, annual report, and other documents.
The EmpCo AI agent extracts all sustainability statements from the web and PDFs in minutes and assigns them to EmpCo topic categories to make potential conflict cases visible.
Each identified claim is prioritized for prominence from a sustainability perspective and professionally assessed by experienced consultants. High-risk cases are prioritized.
Per hit: original wording, EmpCo reference, three tiered strategic action options, and a pre-filled evidence request.
Handover-ready claims register plus a prioritised action roadmap up to the deadline of 2026-09-27.
Results
What the Quick Check includes
A clearly structured results package that provides a concrete path to EmpCo compliance.
AI screening of all sustainability claims
Systematic analysis of your public communication: website, press releases, reports, shop pages, and co-branding materials.
Claims register sorted by risk
Clear Excel register with all identified claims, organized by risk level (high, medium, low).
Detailed analysis by consultants
Each identified statement is professionally evaluated and classified by experienced sustainability consultants.
Three mitigation options per high-risk case
Tiered strategic action options from quick fix to structural solution for every critical statement.
Prioritised action roadmap
Timeline for all measures up to the deadline of 2026-09-27, with clear prioritization and responsibilities.
Handover workshop
Joint workshop with the relevant departments (marketing, CSR, communications) to hand over the results and next steps.
Services
Quick Check vs. baseline assessment
Two service levels for different starting points: from an initial overview to detailed implementation planning.
Recommended as an entry point
Quick Check
Fast, AI-powered overview of your risk situation
Data basis
Public sources
Methodology
AI-powered screening
Effort
2–3 weeks, fixed price
Output
Risk map with standard mitigations
Baseline assessment gap analysis
In-depth review with internal data analysis and a prioritised roadmap
Data basis
+ internal sources (LCAs, PCFs, strategies, …)
Methodology
Manual in-depth review + workshop
Effort
6–8 weeks, effort-based
Output
Prioritised roadmap per claim
Note
The EmpCo Quick Check is a screening and strategy tool for sustainability communication and a supplementary service to our sustainability consulting. It provides a professional risk indication from a sustainability perspective and does not replace legal advice. We do not provide legally binding assessments of individual statements within the meaning of the RDG.
Do you need a legally binding detailed review of individual claims? We can connect you with specialized partner law firms for environmental and competition law.
Do you have questions about implementing EmpCo?
We are here for you!
In a short initial consultation, we will clarify together what scope makes sense for your situation and how the Quick Check can be carried out in practice.
Dr. Martin Granzow
Managing Director and Founder of Nextra Consulting
