EmpCo in online shops: texts, labels and feeds

The basics, deadlines and the German transposition are covered in the guide EmpCo Directive. This guide is about where environmental claims appear in a shop and which rule applies to each.

Where do environmental claims appear in a shop?

The directive defines the environmental claim broadly. It covers any voluntary message or representation in a commercial communication, including pictures, symbols, brand names and product names (Art. 2(o) UCPD). In a shop this affects almost every page type.

Product texts and generic claims

A generic environmental claim is a claim whose specification is not provided “in clear and prominent terms” on the same medium (Art. 2(p)). According to recital 9, the online sales interface counts as the same medium. Without a specification, such a claim is only allowed if recognized excellent environmental performance is demonstrated, for example via the EU Ecolabel (point 4a).

The Commission gives an example in its questions and answers. “Climate-friendly packaging” without further information is a generic environmental claim. “100% of the energy used to produce this packaging comes from renewable sources” is a specific claim. According to the Commission, whether it is permitted depends on the individual case and the evidence. The specification should appear next to the claim or as part of it.

For shops with many products this is mainly a question of text modules. Sentences such as “Responsibly made” often sit in the template and therefore on thousands of pages. Then there is point 4b. A claim about the entire product is prohibited if it concerns only one aspect, for example only the packaging.

Example of a product page

The schematic example shows a product text for a cleaning product. On the left are generic claims, on the right statements with subject, scope and evidence.

For mixtures such as cleaning products that are labeled under the CLP Regulation (EC) No 1272/2008, Art. 25(4) of that regulation also applies. Statements such as “non-toxic”, “non-harmful”, “non-polluting” or “ecological” must not appear on the label or packaging. The Commission points this out in its questions and answers.

Images, badges and filters

According to the Commission, images and colors on their own are not a generic environmental claim. Together with text or a logo, however, they can become part of an environmental claim. A green leaf next to the word “natural” can also act like a label. Point 2a applies to labels.

Badges and filters are text on the sales interface. A “Sustainable” filter says something about all the products in it. For the inventory you therefore also need the rules by which products end up in the filter. Badges and filters often come into the page via JavaScript. They are then missing from the raw source code and only appear in the rendered HTML.

Stock photos and templates for category pages deserve a separate look. A forest image at the top of a category reads differently next to a sentence like “consciously made” than on its own. The Commission names trees, rainforests, water, animals and green or blue backgrounds as examples of images associated with environmental benefits.

Sustainability labels and your own labels

A sustainability label may only be displayed if it is based on a certification scheme or established by public authorities (point 2a). The four criteria for a certification scheme are explained in the guide EmpCo Directive. The Commission clarifies three points.

• The owner of the scheme and the user of the label may be the same company if the scheme is open to all traders and meets the other requirements.
• The third party that monitors compliance must be an entity legally separate from the scheme owner.
• Labels from public authorities outside the EU only fall under the exception if they are based on a certification scheme.

According to the Commission, there is no transition period for existing labels. The table shows what applies to typical labels in a shop.

Checklist per label

For the inventory, one row per label and location helps. The legal assessment stays with the legal department.

• Owner and monitor. Who owns the scheme, and who monitors compliance? According to the Commission, these are two legally separate entities.
• Terms. Where are the scheme's requirements publicly available?
• Subject. Does the label apply to the product, the packaging, an ingredient or the company?
• License. License or certificate number and validity, where the scheme issues them.
• Display. Does the label appear only on products it applies to, including filters, feeds and category pages?
• Evidence. Where is the certificate kept, and who checks that it is still valid?

Product feeds and Google Shopping

Feeds take over texts from the shop or from the PIM. Changing a claim on the product page does not automatically change it in the feed. Feed tools often keep their own fields and rules.

In titles and highlights there is little room for a specification. The Commission's guidance on the UCPD (2021/C 526/01) states that an environmental claim should generally not be made if there is no room for its specification. According to Google, no customer sees custom labels. They only control campaigns.

Example of a feed entry

The schematic example shows an entry for Google Shopping. On the right are only features that can be specified within the feed itself. The reference to the product page adds to the information.

Marketplaces and dropshipping

The UCPD addresses traders. A trader is anyone acting for purposes relating to their trade, business, craft or profession, and anyone acting in the name of or on behalf of a trader (Art. 2(b)). On marketplaces, all content a seller uploads itself therefore belongs in the inventory. That means titles, bullet points, descriptions, images, brand pages and enhanced content such as A+ content.

For marketplace operators, the Digital Services Act contains a specific rule. The hosting liability exemption does not apply to liability under consumer protection law if the platform presents an offer in a way that would lead an average consumer to believe it comes from the platform itself (Art. 6(3) Regulation (EU) 2022/2065). Many marketplaces also have their own rules for product information. Which ones apply is set out in each marketplace's policies.

• Manufacturer texts. Anyone who takes over texts, images and labels from the manufacturer shows them in their own offer. Who is liable in an individual case is governed by national law.
• Marketplace filters. If a product ends up in a category such as “sustainable”, it is worth checking the criteria and who controls the assignment.
• Dropshipping. The seller has often never seen the goods but concludes the contract with the customer. Supplier texts, product photos with nature motifs and labels on the packaging therefore belong in the check. The directive expressly names product packaging as a medium of an environmental claim (recital 9).
• Own brands and white label. According to the Commission, brand names with “eco” or “green” can be an environmental claim if they create an environmental association for the average consumer. The name then needs a specification on the same medium or proof under point 4a.

New mandatory information in the shop

• Harmonized notice on the legal guarantee of conformity, since 27 Sep 2026, laid down in Implementing Regulation (EU) 2025/1960. According to the Commission, in online retail it can appear as a general reminder on the website.
• Harmonized label for the producer's commercial guarantees of durability of more than two years. Online, according to recital 28, it belongs directly next to the image of the product. Immediately before the order is placed, the shop points to it again (Art. 8(2) Consumer Rights Directive).
• Software updates for goods with digital elements. The minimum period is stated as a period or date if the producer provides it.
• Reparability score, where one exists for the product category at EU level. According to the Commission, this has been the case for new smartphones and tablets since 20 June 2025.
• Repair information where there is no such score. This means the producer's information on spare parts, estimated costs, the ordering procedure, repair and maintenance instructions and repair restrictions, where the producer makes it available.
• Environmentally friendly delivery options such as cargo bikes, electric delivery vehicles or bundled shipping, where the shop offers them (Art. 6(1)(g), recital 37).

According to recital 36, the shop is not required to search producers' websites for this information. In practice it arrives via the PIM and product data. If it is missing there, it is missing on the product page too.

Old texts and existing stock

The directive has no general transition period. For goods placed on the market before 27 Sep 2026, Section 15b UWG has applied since that day, promulgated on 27 Oct 2026 (BGBl. 2026 I No. 322). Claims for removal and injunctive relief are then asserted in good faith, balancing seriousness, efforts, costs and environmental impact. The rule applies up to and including 26 Sep 2028 and ceases to apply on 27 Sep 2028. It refers to goods. It does not mention texts on websites. The claims competitors and associations have are shown in the guide EmpCo Directive.

Inventory in five steps

1. Crawl all shop domains and country versions, including JavaScript.
2. Search the rendered HTML, alt texts, titles and meta descriptions with a list of terms approved by the legal department.
3. Find text modules in the template. A finding in the template affects all pages of that type.
4. Export the feeds and marketplace listings and apply the same list to them, including highlights and product details.
5. Pass findings with URL, context and evidence to the legal department and check again after changes.

Common mistakes

• Cleaning up the shop and forgetting the feed.
• Checking only product pages and overlooking filters, badges and transactional emails.
• Searching the raw source code even though badges come via JavaScript.
• Taking over manufacturer texts and supplier images without checking them.
• Showing labels on category pages although they only apply to some products.
• Not documenting the evidence for the claim.

Frequently asked questions