EmpCo and E-Commerce: What Changes for Online Shops, Marketplaces and Dropshipping?

Directive (EU) 2024/825 — known as EmpCo (“Empowering Consumers for the Green Transition”) — applies from 27 September 2026. There is no transition period and no grandfather clause for existing packaging, advertising materials or other marketing assets.

For virtually every online shop selling to consumers within the EU, this means product detail pages, category pages, banners, emails, filter functions and packaging copy must all be compliant by the deadline. Businesses that fail to act in time risk cease-and-desist letters from competitors and consumer associations, and in certain cases fines of up to 4% of relevant annual turnover in the relevant EU market.

This article sets out what the directive means in practice for e-commerce businesses — focusing on the questions online retailers, marketplace sellers and dropshipping operators are asking most right now.

What the directive covers in your shop

EmpCo applies wherever commercial communications are made to end consumers. In e-commerce, that is practically every touchpoint:

• Product detail pages, including titles, description copy, USP bullet points, specifications and FAQ sections
• Category and listing pages with filter options, sort orders and marketing headers
• Marketing landing pages, themed collections, editorial content and advice pages
• Push communications: email newsletters, transactional emails, push notifications
• Header and footer banners, trust elements, informational text in checkout
• Brand pages and About sections, insofar as they promote products or services
• Packaging, inserts, printed invoice copy

Three categories of prohibited claims sit at the centre of the rules:

1. Generic environmental claims such as “sustainable”, “eco-friendly”, “green” or “climate-friendly” are only permissible if the same medium provides a concrete, verifiable explanation of what the claim actually refers to.
2. Carbon-neutrality claims based on offsetting (e.g. CO₂ certificates from reforestation projects) are banned. Terms like “carbon neutral”, “CO₂ neutral” or “climate compensated” are effectively off-limits after the deadline unless they are grounded in actual reductions along the value chain.
3. Sustainability labels without a recognised certification scheme are impermissible. Proprietary brand labels without independent third-party verification are forbidden from the deadline onwards.

Product copy and category pages

The greatest practical effort will be required on product descriptions. Many shops have spent years embedding vague environmental terms into PDP templates and category headers — typically as marketing filler with no substantiation behind it.

That approach stops working after September 2026. The directive requires every environmental claim to be supported by concrete, verifiable information on the same page. A link to an external sustainability brochure, a QR code or a hover tooltip is not sufficient — the evidence must appear on the same medium, clearly and prominently.

Example: PDP for a cleaning product

The key difference: instead of vague marketing buzzwords, there are measurable claims with a defined scope, methodology and source. For marketing teams, this is a mindset shift — from “use as much green language as possible” to “only make claims you can back up with substance.”

What happens to generic boilerplate copy

Many shops use generic marketing copy as boilerplate across hundreds or thousands of product pages. “Shop sustainably with us”, “Our products are kind to the environment”, “Responsibly made.” These claims are particularly high-risk because they often refer to the entire product or range, without any correspondingly broad substantiation behind them.

The directive is unambiguous on this point: an environmental claim about an entire product cannot be made if it only relates to one specific aspect. A retailer who writes “made from recycled material” when only the packaging is recycled is exposed to legal challenge.

Product images and visual signals

The European Commission clarified in its November 2025 FAQ: visual elements can also fall within scope. Purely implicit elements such as colours or images without text do not in themselves constitute a generic environmental claim — but combined with copy or logos, they can become one.

Specifically problematic combinations include:

• Product images featuring green leaves, water droplets, soil or nature motifs, combined with copy such as “natural” or “gentle”
• Entire product ranges presented in green tones with nature photography backgrounds on the category page, positioned as the brand’s sustainability line
• Stylised natural imagery on packaging (e.g. flowering meadows, green globes) that is visible in the PDP gallery
• Homemade “nature” badges or “eco” icons used in product teasers

This is new territory for e-commerce teams. Until now, product photography has been optimised primarily for aesthetics and conversion. Going forward, at least some thought needs to go into asking: where does the visual language, in combination with the product copy, create the impression of an environmental benefit that cannot be substantiated?

Labels and trust logos

From the deadline onwards, sustainability labels are only permissible if they are based on a recognised certification scheme or established by a public authority. This rules out three categories:

• Proprietary brand labels without third-party verification — such as self-designed “We care about sustainability” logos used by large retail chains
• Trade association labels without ISO 17065 or equivalent standards
• Labels from government bodies outside the EU, unless they are based on a certification scheme with independent third-party verification

Recognised labels include, for example, the EU Ecolabel (Regulation EC 66/2010), EMAS (Regulation EC 1221/2009), national Type I ecolabels under EN ISO 14024 (such as the German Blue Angel), FSC, MSC, EU Organic, and many other independently certified standards.

Proprietary labels — what is still possible?

The European Commission has clarified: it is not prohibited for the same actor to be both the scheme owner and the label user — provided the certification scheme meets the formal requirements (open and transparent access for all market participants, third-party verification, ISO conformity).

In practice, this means a manufacturer can maintain a proprietary label, but must open the underlying certification scheme to other market participants and subject it to independent third-party review. For most purely commercial brand labels, this is an extremely high bar to clear.

Practical implications for the PDP

Even a recognised label can become a liability on a product detail page if it appears without explanation. The directive treats the display of a label as an environmental claim in its own right. The recommended approach is to include, for each label:

• Which specific attribute is certified (the product? the packaging? an ingredient?)
• A licence number or certificate ID, ideally with a link to the official verification register of the certifying body
• The methodology on which it is based
• Who issued the certificate

Marketplace sellers: who is liable?

On marketplaces such as Amazon, eBay, Otto, Kaufland or MediaMarkt Marketplace, the key question is: who bears responsibility for environmental claims — the marketplace operator or the individual seller?

The short answer: both, depending on the circumstances. The directive governs commercial practices in the B2C relationship. For the seller as the party placing goods on the market, it is clear that they are responsible for their own claims — regardless of whether they sell via their own domain or through a marketplace. Platform operators may face their own obligations depending on the situation, under platform regulation and consumer protection law.

What marketplace sellers need to keep in mind

• Review your own listings: Titles, bullet points, descriptions, A+ content, brand pages — anything you populate yourself comes back to you.
• Question manufacturer copy you’ve taken on trust: If you list products using manufacturer-supplied text and that text contains vague “sustainability” claims, you as the seller bear responsibility for its content. The manufacturer’s loose environmental claims in the product copy become your problem, not theirs.
• Watch the marketplace’s own filters: If your product is included in the marketplace’s “Sustainability” or “Climate-friendly” filter categories, your listing may be displayed in a context that implies an environmental claim. Regularly check which filter contexts your products appear in.
• Reviews, Q&A, external integrations: These fall primarily under the platform operator’s responsibility, but can reflect back on the seller when actively promoted.

What marketplace operators will do

It is reasonable to expect that larger marketplaces will roll out their own compliance tools from summer 2026 onwards — automated scans of listings for prohibited terms, mandatory evidence fields for environmental claims, and restrictions on filter categories such as “Carbon Neutral.” Sellers should monitor platform communications closely in the coming months and update their listings in good time.

Dropshipping: responsibility without product control

Dropshipping operations face a particularly awkward position under EmpCo. The retailer typically never handles the products directly, and takes over product descriptions, images and sometimes packaging copy from the supplier — yet remains the seller of record to the end customer and therefore responsible for the commercial communication.

Specific risks in the dropshipping model

• Supplier copy: If you take product descriptions from a wholesaler and they contain blanket “eco-friendly” or “sustainable” claims, you are liable for those claims just as if you had written them yourself.
• Packaging outside your control: If the product arrives at the customer in packaging bearing uncertified sustainability labels or generic environmental claims, that is a risk. Unlike the Packaging Act (LUCID), where dropshippers often do not qualify as manufacturers, EmpCo focuses on commercial communications made to consumers — and that includes the packaging that ships with the product.
• Supplier imagery: Product photos provided by the supplier that feature natural motifs, eco symbols or homemade eco badges are subject to the same rules as self-produced content.
• White-label products with “green” brand names: A white-label product with a brand name like “GreenLine” or “EcoChoice” is only permissible, per the European Commission’s FAQ, if the brand name meets the requirements for generic environmental claims or certified labels.

Product feeds: Google Shopping, Meta, marketplace exports

One blind spot that almost every shop has: its product feeds. Content that is visible in the shop is automatically pushed out to external platforms via feeds — reproducing the problematic claims there, often in an even more concentrated form, because feed fields are shorter and buzzwords appear more prominently.

Typical feed destinations that fall within EmpCo’s scope:

• Google Merchant Center / Google Shopping — product titles, descriptions, custom labels, highlights
• Meta Commerce Manager for Facebook and Instagram Shopping
• TikTok Shop, Pinterest Shopping, YouTube Shopping
• Marketplace exports to Amazon, eBay, Otto, Kaufland, Galaxus, Idealo
• Affiliate networks such as Awin, Tradedoubler, AdCell — which are supplied with product data
• Price comparison feeds (Idealo, billiger.de, Geizhals)
• Price search engines and voucher platforms receiving product data via feed

Why feeds are a particularly underappreciated compliance risk

Three reasons make product feeds an underestimated compliance issue:

Feeds replicate claims automatically. Removing a carbon-neutrality claim from your shop does not automatically remove it from your feeds. PIM systems, feed management tools like Channable, Productsup or Lengow often retain old fields, static copy or calculated fields that continue to carry the problematic claims — even after the source has been corrected.

Feed titles are especially condensed. In the shop, a product might read “Cleaning product — biodegradable, in 70% recycled packaging.” In the feed, this often becomes “Bio cleaning product eco-friendly carbon neutral” — because marketing teams use feeds for keyword stuffing to maximise search and ad visibility. The compressed, punchy format is particularly prone to generic claims without any substantiation.

Substantiation is absent in the feed. Even where the shop page provides the necessary evidence (methodology, licence number, source reference), most feed formats have nowhere to put it — the field simply doesn’t exist. A claim like “manufactured carbon-neutrally” appears in the feed in isolation, stripped of the evidential context available on the PDP.

Example: a typical Google Shopping listing

Specific risks on Google Shopping

Google has signalled on several occasions in recent years that it intends to take action against greenwashing in Shopping ads — its own policies may follow, but the primary pressure comes from the legal landscape. Specific areas to review in Google Merchant Center:

• Product titles with buzzwords: “organic”, “sustainable”, “carbon neutral”, “eco” — widespread as keyword stuffing in titles, and particularly high risk
• Custom labels used for filtering logic: Setting “Custom Label 0” to “sustainable” in order to appear in corresponding Smart Shopping campaigns effectively functions as a self-awarded label
• Promotional highlights: These short bullet-point texts function like mini-labels and are subject to the same substantiation requirements
• Product images with nature motifs: Feed images also fall within scope. Gallery images featuring green leaves or natural settings can be read as an implicit environmental claim when combined with the title copy
• Embedded manufacturer fields: Where the manufacturer sets eco-claims within the feed, the retailer assumes responsibility the moment they pass the feed on

Marketplace feeds and the dual obligation

With marketplace feeds (Amazon, Otto, Kaufland), a particular dynamic arises: the seller is responsible for their own content, but the marketplace operator is increasingly running its own checks. Submitting listings with problematic terms risks not only cease-and-desist letters from competitors, but also automated platform penalties — suspended listings, reduced visibility, loss of Buy Box status on Amazon.

Larger marketplaces will likely roll out their own compliance filters in the months before and after 27 September 2026. Retailers who don’t clean up their feeds in time are exposed not just to legal consequences, but to direct revenue loss through platform-imposed restrictions.

Filters, badges and tagging

Filter and tagging structures within the shop are another frequently overlooked area. Environmental claims can arise here indirectly — through UI architecture rather than individual copy.

Examples of problematic UI elements

• Filters like “Sustainable products” or “Eco”: Which products end up in this filter, and on what criteria? If the assignment is opaque or based purely on commercial considerations, it constitutes an implicit environmental claim about the filtered products.
• Badges like “Climate-friendly” or “Reduced CO₂” on product teasers: These function as mini-labels and are subject to the same rules as formal sustainability labels.
• Trust sections with brand promises: “We’re thinking about tomorrow” or “Responsibility for the environment and society” as footer banners on every page are read as a company-wide environmental claim — and are therefore subject to the strict substantiation requirements.
• SEO copy and editorial content: Advice articles, guides, blog posts and SEO copy on sustainability topics also fall within scope if they reference specific products or the shop’s own range.

No grandfather clause for existing products and old copy

The directive includes no grandfather clause and no transition period. Even copy that has been live for years must be compliant from 27 September 2026.

The European Commission has clarified in its FAQ, however, that national authorities may take proportionality and legitimate expectations into account when making assessments — for instance, where a retailer can demonstrate that they made reasonable efforts to bring products further down the supply chain into compliance as well. That is not a free pass, though — at best, it is a mitigating factor in dispute proceedings.

In practice, this means a systematic audit of the entire website is unavoidable. At 50,000+ products, that cannot be done manually — this is where automated screening tools come in.

What you should do now

Five months remain until the deadline. Businesses that act now in a structured way have a realistic chance of achieving full compliance in time. A recommended roadmap:

1. Stocktake: Which terms, labels and claims appear where on the website? For larger shops, this requires an automated crawl-and-screening setup.
2. Risk prioritisation: Start with the highest-risk claims (carbon-neutrality assertions, generic terms without evidence, unverified proprietary labels). Address medium-risk issues (specific claims without a clear source) in a second pass.
3. Secure your evidence: For every environmental claim you want to keep, you need a traceable chain of evidence: studies, lifecycle assessments, certificates, methodology documentation. If the evidence doesn’t exist, the claim must be removed or rewritten.
4. Revise copy: Either back generic terms with concrete, verifiable information on the same page — or remove them altogether. Note: brand names and product names containing terms like “Eco” or “Green” also fall within scope.
5. Review images and visual elements: Audit category pages and PDP galleries for implicit environmental signals. When in doubt, replace nature-themed imagery with neutral product shots.
6. Establish ongoing monitoring: Compliance review is not a one-off project. Every new product launch, every marketing campaign, every A/B test variant can introduce new risks. Continuous monitoring prevents fresh violations from creeping in after 27 September 2026.
7. Legal review of critical cases: High-risk findings should be assessed by a specialist commercial law firm — particularly in grey areas around implicit claims, proprietary brand labels and substantiation requirements.