If your website says "eco-friendly," "sustainable," or "conscious collection" anywhere — on a product page, in an Instagram caption, on a hang tag — you have until September 27, 2026 to fix it. That's not a suggestion. It's EU law.
Anti-greenwashing regulation is about to reshape how every fashion brand communicates sustainability. The Empowering Consumers for the Green Transition Directive (known as EmpCo) becomes enforceable across the EU in less than six months. It doesn't introduce new environmental standards. It does something more disruptive: it bans the marketing language that most fashion brands rely on to communicate sustainability — unless that language is backed by specific, verifiable evidence.
This article explains what the directive actually prohibits, how it connects to the Digital Product Passport, and what you need to change before September.
EmpCo amends the EU's existing Unfair Commercial Practices Directive — the framework that's been protecting consumers from misleading marketing since 2005. The amendment adds a specific set of greenwashing practices to the "blacklist" of prohibited commercial behaviours.
Here's what's banned from September 27, 2026.
Generic environmental claims without substantiation. Terms like "eco-friendly," "green," "sustainable," "environmentally responsible," or "natural" are prohibited unless they're accompanied by recognised certification or clear, specific evidence that the consumer can verify. Saying "our t-shirts are sustainable" is no longer acceptable. Saying "our t-shirts are made from 100% GOTS-certified organic cotton, manufactured in a facility audited to SA8000 standards" is fine — because it's specific and verifiable.
Climate-neutrality claims based on carbon offsetting. You can no longer call a product "carbon neutral," "climate neutral," or "climate positive" if that claim relies on purchasing carbon credits to offset emissions rather than actually reducing them. This is a major shift for brands that have built their sustainability messaging around offset programmes.
Self-created sustainability labels. If you designed your own green badge or eco-label and put it on your products or website, it's no longer permitted — unless it's based on a recognised third-party certification scheme or established by a public authority. Company-created logos that suggest environmental or social benefits without independent verification are explicitly banned.
Environmental claims about the entire product based on a single attribute. Claiming a garment is "sustainable" because it uses recycled polyester — while ignoring the fact that it's manufactured using heavy water and chemical processes — is misleading and prohibited. Claims must reflect the overall environmental profile, not cherry-pick one positive feature.
Here's what's still allowed.
Specific, substantiated claims. "Made from 70% recycled polyester" is fine — it's specific, measurable, and verifiable. "Manufactured in Portugal using renewable energy" is fine — it's a factual statement about a specific attribute. "OEKO-TEX Standard 100 certified" is fine — it references a recognised third-party certification.
Honest communication about sustainability efforts. You can still talk about your sustainability journey, your reduction targets, and your improvement plans — as long as you don't frame them as current product attributes when they're actually aspirational goals.
The principle is straightforward: say what you can prove, at the product level, with evidence a consumer or regulator could verify.
The anti-greenwashing directive and the Digital Product Passport are two separate pieces of legislation, but they're designed to work together. The directive tells brands what they can't say. The DPP provides the infrastructure to prove what they can.
Think of it this way. Under EmpCo, if you claim your garment is "made from organic cotton," a regulator or competitor can challenge you to produce evidence. Without a DPP, that evidence might be buried in a supplier email from two years ago, a certificate you're not sure is current, or a tech pack that's stored on someone's laptop.
With a DPP, the evidence is structured, digital, and publicly accessible. Your passport contains the material composition with exact percentages, the certification document linked to the specific product, the manufacturing origin, and the SVHC compliance statement. When someone challenges your claim, the proof is one QR scan away.
This is why the DPP isn't just a compliance obligation running in parallel to the green claims rules — it's the verification mechanism that makes compliant sustainability marketing possible. The brands that have their DPP infrastructure in place by September 2026 will be able to market their sustainability credentials with confidence. The brands that don't will need to either strip their marketing of all environmental language or risk enforcement action.
One of the most common greenwashing mistakes in fashion isn't intentional deception — it's sloppy certification management.
Here's how it happens. A brand sources GOTS-certified organic cotton for a product line. They mention GOTS certification on their product page and hang tags. Two years later, the certification has expired, or the supplier has changed, or the specific fabric used is no longer covered by the original scope certificate — but the marketing language hasn't been updated. The claim is now unsubstantiated.
Under EmpCo, this is a violation. The fact that it was accidental doesn't matter. The claim is either substantiated or it isn't.
The DPP solves this by treating certifications as structured data, not marketing copy. When you upload a certification document in your DPP platform, it's linked to specific products, it has an expiry date, and the platform can flag when it needs renewal. If the certification lapses, the passport can be updated to reflect the change — either by uploading the renewed certificate or by changing the claim to "self-declared" (which is honest but less commercially appealing, and therefore a strong incentive to keep certifications current).
The key takeaway: start treating your certifications as managed data assets. Know which products they cover. Know when they expire. Know whether the current production run is still within the scope of the certificate. Your DPP platform should make this easy — if it doesn't, our platform evaluation checklist can help you assess alternatives.
Before September 2026, every fashion brand should audit their customer-facing communications for compliance with the new rules. Here's what to look for.
Website product pages. Search your product descriptions for generic terms: "eco-friendly," "sustainable," "green," "conscious," "eco," "earth-friendly," "planet-positive." For each instance, ask: can I point to specific, verifiable evidence for this claim? If not, rewrite it.
Hang tags and packaging. Do any of your physical materials carry self-created sustainability badges, green logos, or eco-labels that aren't based on recognised third-party certifications? If so, remove them.
Social media and advertising. Review your Instagram posts, Facebook ads, and newsletter copy for environmental claims. "Our most sustainable collection yet" is problematic unless you can define and substantiate what "most sustainable" means.
Home page and about page. Generic statements like "we're committed to a more sustainable future" are likely fine as aspirational messaging. But "we make sustainable clothing" is a product claim and needs substantiation.
Carbon neutrality claims. If you've claimed your brand or any products are "carbon neutral," "climate neutral," or "net zero" based on offset programmes, these claims must be removed or fundamentally reworded. You can say "we invest in verified carbon removal projects" — you can't say "our products are carbon neutral."
Certification references. For every certification you mention (GOTS, OEKO-TEX, Bluesign, Fair Trade), verify that the certificate is current, covers the specific products referenced, and that you have the documentation on file.
See our DPP data requirements guide for the full list of fields.
Stripping your marketing of all environmental language isn't the answer. You've invested in sustainable materials, ethical manufacturing, and responsible practices — you should be able to communicate that.
The shift is from vague to specific. From generic to verifiable. From narrative to data.
Instead of "sustainable fashion," try "made from 95% organic cotton, GOTS certified, manufactured in Porto, Portugal." Instead of "eco-friendly packaging," try "packaged in FSC-certified recycled cardboard, no plastic components." Instead of "our most conscious collection," try "every product in this collection carries a Digital Product Passport — scan the QR code to see exactly where it was made and what it's made of."
Notice the pattern. Every compliant claim points to a specific, verifiable data point. And every one of those data points is exactly the kind of information your DPP contains.
This is the fundamental connection between anti-greenwashing regulation and the Digital Product Passport. The DPP isn't just a regulatory obligation — it's the evidence base that makes honest, credible, legally compliant sustainability marketing possible and builds genuine consumer trust through transparency. Without it, you're either stripping your marketing bare or gambling on enforcement.
September 27, 2026 is the enforcement date. That's less than six months away. Here's what that means in practical terms.
EU Member States are required to transpose the directive into national law by March 27, 2026 — that deadline has already passed. Some countries may still be finalising implementation, but the direction is locked in and the enforcement date is firm.
There is no transition period after September 27. From that date, any non-compliant environmental claim is subject to enforcement action by national consumer protection authorities. Penalties can include fines of up to 4% of annual turnover in the relevant Member States, confiscation of revenues from transactions associated with misleading claims, and mandatory corrective actions (rewriting marketing, removing labels, issuing public corrections).
The directive also empowers competitors to take action. If your brand uses vague green language while a competitor invests in genuine, verifiable sustainability data, they can file an unfair competition complaint against you. In Germany, the Wettbewerbszentrale (competition watchdog) has already initiated over 100 proceedings against misleading environmental claims.
This isn't a future risk. It's a present one. The brands that clean up their marketing now and build the DPP infrastructure to back up their claims will enter September 2026 with confidence. The ones that don't will be exposed.
Scan or click to see what verified product data looks like in a DPP
Build the evidence base for your sustainability claims.
This article reflects the regulatory landscape as of April 2026. National transposition of the EmpCo directive may vary by Member State. Stay informed.
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