EmpCo for Corporate Groups: What Multi-Brand Companies Need to Address Now

The Empowering Consumers Directive (EU) 2024/825 applies wherever commercial communications are directed at end consumers. For corporate groups with multi-brand portfolios, this creates a distinct set of challenges that differ from standard e-commerce setups in three ways: a larger number of parallel website types, a more indirect relationship with end consumers, and an overlap with CSRD reporting where sustainability disclosures and marketing claims increasingly blur together. This article provides a structured overview of the key challenges and explains how technical tooling can make compliance processes scalable.

Scope: What actually falls under the directive

The directive covers any form of commercial communication directed at consumers. For corporate groups, that includes:

• Group websites with product or brand references
• Brand microsites and all product experience pages
• Press releases and newsroom content that present products or brands favorably
• Marketing campaigns and advertising across all channels (online, OOH, broadcast)
• Social media posts on group and brand accounts
• Product packaging and accompanying materials
• Brand names and product names with environmental connotations (“EcoLine,” “GreenChoice,” “ClimateCare”)

Out of scope: purely internal communications, B2B communications without consumer reach, technical data sheets for business customers, and mandatory reports (CSRD) in their original form as addressed to investors.

Group website and umbrella brand claims

Group websites regularly feature sweeping umbrella brand statements: “We are the most sustainable company in our industry” or “Responsibility for the environment and society is part of who we are.” From 27 September 2026, these statements are subject to the same requirements as specific product claims — they must be substantiated, must not be exaggerated or misleading, and cannot refer broadly to the entire business if only part of it is covered.

Example: Typical corporate hero statement

The status of carbon neutrality claims at the corporate level

“Carbon-neutral company” or “carbon-neutral production” can no longer be used at the product or business level if the claim is based on offsets. What remains permissible are so-called contribution claims — statements that transparently describe a company’s support for climate projects without attributing neutrality to the product or the business itself. Formulations that tend to be acceptable, provided they are properly substantiated:

• “We invest X euros per year in certified climate protection projects (standard: Gold Standard / VCS)”
• “We support reforestation initiatives in [region] together with [partner] — verified under [standard]”
• “Through our offset partnership with [partner], X tonnes of CO₂-equivalent were sequestered in [project] in 2024 — see report”

Generic language without a specific project, partner, and standard reference is not sufficient. Claims that remain prohibited after the deadline include: “Carbon-neutral products,” “We produce CO₂-neutrally,” “Climate-neutral through offsetting,” and “Climate-positive supply chain.”

Brand microsites: Three common risk areas

1. Inconsistent language across brands

Brand A uses “carbon neutral” (prohibited), Brand B uses “we invest in climate protection projects” (permissible), Brand C uses “100% climate-friendly” (problematic). The corporation sends contradictory messages to the same consumer. That’s not just a compliance issue — it signals that brand governance is missing. A group-wide glossary of approved and prohibited formulations is the single most immediately effective measure here.

2. Proprietary brand seals without third-party verification

Many corporate groups have introduced their own sustainability labels for individual brands: “Conscious Choice,” “Care Line,” “Green Edition,” “Eco Pro.” From that date onward, these proprietary seals are only permissible if they are based on a recognised certification scheme with independent third-party verification. Requirements include open and transparent access for other market participants, ISO-compliant third-party auditing, and publicly accessible criteria. Very few existing brand seals actually meet this threshold.

3. Brand and product names with environmental connotations

Brand names such as “EcoBrand,” “Climate Care,” “Green Future,” or “Naturals” are explicitly covered by the directive according to European Commission FAQ guidance — even where they are trademarked. They are subject to the same requirements as generic environmental claims. In cases of non-compliance, trademark registration can be challenged on grounds of unfair competition law. Groups with long-established “green” brands in their portfolio should have these positions reviewed legally, and should maintain substantiated evidence on the relevant brand websites and packaging.

The CSRD overlap: When reporting language becomes advertising

Mandatory CSRD reports are generally outside the scope of the Empowering Consumers Directive, since they are statutory and not directed at consumers. In practice, however, the boundary rarely holds — which creates a systemic risk:

• CSRD statements are repurposed as marketing soundbites in press releases
• Sustainability reports are linked and promoted on consumer-facing websites as trust signals
• Individual metrics from reports (“42% reduction by 2030”) migrate into advertising, marketing hubs, and social media
• CSRD content appears in speeches, interviews, and blog posts, reaching consumers directly

Once any of that happens, EmpCo rules apply. A statement that was adequately contextualised in a CSRD report — backed by methodology, data sources, and auditor sign-off — can become misleading in a marketing banner, because that context is gone. Corporate groups need an explicit governance policy: which CSRD statements may move into which channels, and what substantiation context must travel with them.

Press releases, newsrooms, and social media

Press releases are typically managed by corporate communications teams, not compliance departments — yet they can qualify as commercial communications under the directive as soon as they present products or brands favorably. Three specific risk areas:

• Carbon neutrality claims in archived press releases: “Group X transitions production to carbon-neutral energy” — if the claim is based on offsets, it is problematic from the deadline onwards. That applies to previously published press releases that remain online unchanged, since they continue to be visible and are therefore still active communications.
• Extensive archives: Many corporate groups maintain newsroom archives with hundreds or thousands of entries spanning several years — fully searchable and SEO-indexed. Consumer associations and competition watchdogs actively search old content. Systematically screening legacy archives is a compliance requirement, not optional.
• Social media volume: LinkedIn, Instagram, Facebook, X — individual brands can easily generate thousands of posts per year, often featuring green imagery, nature motifs, and unsubstantiated buzzwords. Older posts remain publicly visible and can be challenged.

Product data sheets and retailer responsibility

Manufacturers supply retailers with product data, descriptions, and images through data sheet portals, PIM systems, or marketing hubs. When these materials contain problematic environmental claims, the risk does not sit solely with the retailer — it also sits with the manufacturer. The reasoning: anyone who knows or should know that their product descriptions will be passed on to consumers shares responsibility for their compliance. The consequence: PIM databases and marketing asset portals need to be screened just as systematically as consumer-facing websites. For corporate groups with large brand portfolios, that typically means thousands of products across dozens of brands.

B2B communications: Where the line falls

The directive targets B2C communications. Purely B2B materials — technical data sheets for business customers, quotations, internal sales collateral — do not fall under it directly. But the boundary is more blurred than it first appears:

• Publicly accessible B2B content: Freely downloadable data sheets on a website can reach consumers and therefore fall within the scope.
• B2B materials that flow into B2C communications: Marketing templates that manufacturers provide to retailers for end-consumer communications are EmpCo-relevant.
• General competition law: Even where EmpCo does not directly apply, the UWG remains applicable. Misleading claims in B2B contexts can be challenged on other legal grounds.

A sensible working approach: B2B content with potential consumer visibility should be treated similarly to B2C communications. Access-restricted, purely internal B2B communications have more room to manoeuvre — but are not fully exempt.

The scale problem: Why manual review isn’t enough

The volume of content that a typical multi-brand corporate group produces far exceeds the capacity of conventional audit approaches: A traditional external audit — by a law firm or consulting agency — takes weeks to months and typically typically runs to six-figure fees. The output is a snapshot, not ongoing monitoring. And content changes constantly: new campaigns, brand launches, updated product descriptions. What was reviewed today can introduce new risks next week.

Technical tooling: What’s possible today

The volume and continuity challenges described above can be addressed systematically with automated, AI-assisted screening solutions. Core requirements for EmpCo-ready tooling at corporate scale:

Cross-domain crawling

The tool needs to cover all domains and subdomains across the group — group website, brand microsites, regional variants, careers portals, product data sheet portals. Many corporate groups don’t actually know exactly how many active subdomains they’re running. Automated crawling first creates a complete domain inventory as the foundation for everything that follows.

Semantic risk detection

Simple keyword matching — “carbon neutral,” “sustainable,” “eco-friendly” — is not sufficient. Problematic claims are often contextual: the same formulation can be compliant in one context and misleading in another. Capable tools use semantic analysis to evaluate statements in context and prioritise them by risk level: high risk (immediate action required), medium risk (review needed), low risk (document, no urgent action).

Cross-channel tracking for CSRD statements

A tool that tracks which statements from CSRD reports have migrated into which marketing channels directly addresses the CSRD overlap outlined above. It enables compliance teams to monitor how reporting language moves into advertising materials and verify that the necessary substantiation context travels with it.

Change monitoring

A one-time screening is not enough. The tool needs to continuously monitor new and updated content and alert compliance teams when risky formulations appear. This is especially important for social media and press releases, where content is published without a mandatory compliance sign-off process.

PIM integration

To address the retailer responsibility dimension, the tool should ideally be able to scan product data directly from the PIM system — not just the consumer-facing website. This way, problematic claims are caught before they reach consumers through retail channels.

Tooling’s role in the overall strategy

Automated screening does not replace legal judgment. It makes legal assessment scalable — by reducing the volume of content that needs to be reviewed to the cases that actually carry risk, prioritising them, and routing them to the right teams. The compliance team focuses on decisions, not on manual searching.

Recommendations for corporate groups

Five months remain until the 27 September 2026 deadline. With a clear roadmap, that’s workable — but only if you move now.

1. Build a domain inventory — Map all websites in the group: group site, brand microsites, regional variants, careers portals, product data sheet portals. Automated crawling is faster and more complete than manual research.
2. Audit content across all domains — Crawl-based: which terms, seals, and claims appear where? Per brand, per language, per market.
3. Prioritise by risk level — High risk first: carbon neutrality claims, generic unsubstantiated terms, unverified proprietary brand seals. Medium risk in the second pass.
4. Make CSRD migration visible — Which CSRD statements are being used in marketing channels? Where is the substantiation context secured, and where is it missing?
5. Update brand governance — Clear approval workflows for new brand statements involving compliance, legal, and sustainability teams. A group-wide glossary of approved and prohibited formulations.
6. Clean up press release archives — Archive, unpublish, or add update notices to entries containing high-risk claims.
7. Review brand and product names — Have brands with environmental connotations (“Eco,” “Green,” “Climate”) reviewed for legal compliance. Where there’s risk: consider repositioning or maintain substantiated evidence on the brand website.
8. Clean up PIM and marketing asset databases — Not just consumer-facing websites, but also materials passed on to retailers.
9. Establish ongoing monitoring — Compliance is not a one-time project. Every new campaign, brand launch, or regional adaptation can introduce new risks. Continuous, automated screening prevents new violations from emerging after the deadline.
10. Get legal review on critical cases — Have high-risk findings assessed by a specialist law firm — especially in grey areas around implied claims, proprietary brand seals, and the CSRD overlap.