EmpCo: What It Means for Print, Paper and Paper Packaging

The EU’s Empowering Consumers for the Green Transition Directive (EmpCo) will change how environmental claims are made to consumers. The main message is clear: sustainability claims need to be specific, substantiated and transparent.

With the rise in consumers awareness of sustainability, environmental messaging such as “green”, “eco-friendly” or “carbon neutral” have appeared frequently in consumer products, marketing and websites. But from 27^th September 2026, businesses marketing to consumers in the EU will need to take a closer look at what these terms mean.

Two Sides has already challenged more than 1,500 businesses over unsubstantiated or misleading environmental claims relating to print and paper. EmpCo takes this issue further, introducing new rules designed to protect consumers from misleading environmental claims and sustainability labels.

The important thing to note is that the new legislation does not stop businesses from marketing their sustainability, it’s about making sure the messages are communicated accurately and can be supported by evidence.

The print, paper and paper packaging sector has many environmental credentials, but its important they are communicated in the right way.

What is EmpCo?

EmpCo amends existing EU rules on unfair commercial practices and introduces new requirements around environmental claims and sustainability labels. The aim is to make sure consumers are not misled by broad or unsupported environmental messages.

The Directive defines an environmental claim very broadly. It can include not only words, but also images, graphics, symbols, labels, brand names and product names used in commercial communications. In the Directive’s own words, an environmental claim can be “any message or representation … in any form” that suggests a product, brand or business has a positive or reduced environmental impact.

For the print, paper and paper packaging sector, this means businesses need to look beyond the sustainability section of their website. Environmental claims can appear on packaging and product labels, in specifications and brochures, across websites and social media, in advertising and sales materials, and through environmental logos and imagery.

Making environmental claims clearer

One of the key changes under EmpCo is the treatment of generic environmental claims such as “eco-friendly”, “green”, “climate-friendly” and “biodegradable”. Rather than making broad statements, businesses should clearly explain the specific environmental benefit being claimed and ensure it can be substantiated. For example, the Directive distinguishes between a generic claim such as “climate-friendly packaging” and a specific statement such as “100% of the energy used to produce this packaging comes from renewable sources.” This is particularly relevant to paper and packaging, where claims may relate to recycled content, fibre sourcing, recyclability, energy use or emissions. The examples below illustrate how broad claims can be made more specific:

Future commitments

The claim “We will be carbon neutral by 2030” might be seen as a simple aspiration, but it is not when it is used as an environmental marketing claim. EmpCo introduces requirements around future environmental performance claims. The directive requires such claims to be supported by objective, verifiable commitments with a detailed and realistic implementation plan that is measurable and time bound. The plan must also be regularly verified by an independent third-party expert and the findings available to the public.

How can the Paper, Print and Packaging Sector prepare?

1. Consider your environmental statements

Review websites, packaging, brochures, specifications, social media, advertising and sales materials for environmental messaging, don’t forget graphics and logos.

2. Define what each message means

If the business uses “sustainable paper”, for example, establish exactly which environmental characteristic is being communicated.

If the answer isn’t clear internally, it is unlikely to be clear to a consumer.

3. Match every claim to evidence

Create an evidence file for each environmental claim.

Depending on the claim, evidence could include certification, chain-of-custody documentation, technical data, testing, lifecycle assessment, supplier information or independently verified calculations.

4. Check the scope
   

   Ask whether the claim applies to:

• the entire product
• a component
• the manufacturing process
• a particular material
• the whole business

Make the scope explicit.

5. Put approval controls in place

Environmental claims should not be created and published without access to the evidence supporting them. A straightforward process could be:

• marketing
• technical/sustainability review
• compliance/legal review
• approval
• evidence archived.

This creates a record of why a claim was made and what supports it.

A new era for environmental communications

Navigating new legislation can feel frustrating and complex, particularly when businesses are trying to understand which claims need changing, what evidence is required and how the rules apply to different products and markets. There is no simple checklist that will cover every situation. The starting point is to look carefully at the claims being made, understand what they mean and ensure they are supported by appropriate evidence.

EmpCo does not mean that print, paper and paper packaging businesses must stop talking about sustainability. For an industry with a substantial body of scientific, technical and certification evidence behind its processes, the new rules provide an opportunity to communicate those attributes more clearly and confidently.

Two Sides can also help businesses navigate these conversations. We provide evidence-based facts and information on the environmental and sustainability attributes of the print, paper and paper packaging industries. Two Sides members have access to resources including our Myths & Facts, Packaging Facts booklet and a range of industry fact sheets, which can help businesses understand and substantiate environmental claims. If you need further guidance on environmental communications or the resources available to members, please contact enquiries@twosides.info.