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Navigating the EmpCo Directive

What It Means for Your Purchase

The EU's EmpCo Directive (officially Directive (EU) 2024/825, Empowering Consumers for the Green Transition) was created to close the gap between promises and practice. It specifically targets green washing, which involves misleading, exaggerated, or unsubstantiated environmental claims designed to make a company or product appear more sustainable than it actually is. It requires businesses to back up sustainability claims with real, verifiable evidence. It is no longer just about the language of green marketing, but also the evidence that supports it. The goal is straightforward: to give consumers clear, accurate information about the social and environmental impact of what they buy, so sustainability can genuinely factor into purchasing decisions rather than becoming a guessing game. Failure to comply could erode customer trust and prompt regulatory bodies to step in.

We've all met the watch salesman. "Need a watch?" he asks, holding up something that looks suspiciously like it fell off a truck. You know not to trust the pitch. Lately, claims of "resilience", "eco-friendly", and "sustainable" have started to feel the same way: shifty, unreliable, and like counterfeit versions of genuine climate preservation efforts.

What is a Green Claim?

Green claims are written or oral statements directed at customers that imply a product, service, or organisation has a neutral, reduced, or positive impact on the environment. These claims give the impression that a purchase contributes to a more sustainable economy, when in actuality, they may simply target consumers' desire to make environmentally conscious decisions. The EmpCo Directive targets misleading claims regarding environmental impact and durability, particularly terms such as "eco-friendly" or "climate neutral", as well as self-certified sustainability labels.

If a company wants to advertise environmental benefits, it must specify exactly which component of the product is environmentally beneficial and which parts of the supply chain are involved. Furthermore, supporting evidence for these claims must be publicly available and verifiable, including through Digital Product Passports (DPPs), where applicable.



EmpCo applies to business-to-consumer (B2C) companies across the EU and comes into effect on 27 September 2026. From that date, environmental and sustainability claims made in advertising, packaging, and product descriptions must meet its standards, with no transition period for existing products.

Key Requirements

  • Substantiation: Environmental claims must be backed by evidence that is clear, verifiable, and specific to the product or company being described. Vague or unqualified terms like "eco-friendly" or "green" are no longer enough on their own.
  • No misleading future claims: Statements about future environmental performance (e.g. "climate neutral by 2030") must be supported by a concrete, verifiable action plan, not just an ambition.
  • Ban on unsubstantiated general claims: Broad claims like "environmentally friendly" or "sustainable" are prohibited unless they can be demonstrated for the whole product or company, rather than just one aspect of it.
  • Sustainability labels and certifications: Labels must be based on independent, transparent certification systems. Self-created or unverified "seals of approval" are restricted.
  • Durability and reparability information: Consumers must be given clear information about a product's expected lifespan and repairability, helping to address premature obsolescence.
  • Product lifecycle transparency: Claims about a product's environmental footprint need to reflect its full lifecycle, from raw materials and manufacturing (take, make) through use and disposal, rather than focusing on just one flattering stage.

Note that EmpCo applies to business-to-consumer communication. If you sell packaged flour, feed, or food directly to consumers, you are directly affected. If you sell B2B, expect your own customers and retailers to start asking for proof behind any claims you provide to them.

How This Affects Our Clients

Many producers have spent years building sustainability messaging into their brands, from packaging and websites to retailer presentations. Much of this wording may now need to be reviewed. The risks of getting it wrong include fines, reputational damage, and the cost of reworking labels and marketing materials.

But this is also a chance to take a closer look at what your operation actually achieves. Companies that can measure their energy use, product losses, and process efficiency are in a far stronger position than those relying on broad statements.

How We Can Help

At Castle Ingredients, sustainability is built into how we work, and we can help clients turn real performance into claims that stand up to scrutiny:

  • Efficient equipment: Our milling and processing machines are designed to reduce energy consumption and product waste, and we can provide measurable data on their performance.
  • Better yields: Higher extraction rates and lower product losses mean more output from the same raw material, a benefit you can quantify and communicate.
  • Evidence you can use: We can support clients in documenting and verifying performance so their claims are specific, accurate, and defensible.
  • Real-world testing: Our pilot facility lets clients trial processes using their own materials and generate actual figures, rather than relying on estimates.

Specific, measurable results are exactly what the directive rewards.

Our facilities are powered by 6.45 MWc of photovoltaic solar panels and rely entirely on dry processing of ingredients. Dry processing avoids the large volumes of water consumed by conventional wet processing, reducing a significant source of waste in production. Our plant also exclusively processes vegan ingredients to create vegan products, reflecting our commitment to a more sustainable mode of consumption.

Turning Compliance into an Advantage

The EmpCo Directive presents an opportunity to increase consumer trust, enhance brand reputation, future-proof operations against evolving market expectations, and respond to increasingly stringent regulatory demands. As vague claims disappear, the companies that stand out will be those with credible, evidence-based sustainability data. Instead of saying a product is "green", you can explain how much energy a process saves or how much waste it avoids. Ultimately, transparency builds trust with retailers, regulators, and consumers alike.

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