EmpCo Directive: EU Member State implementation tracker

Directive (EU) 2024/825, known as EmpCo, codifies EU rules on greenwashing and early obsolescence of consumer products. Member States had to adopt national laws implementing EmpCo by 27 March 2026, and apply them from 27 September 2026. Both dates have passed, but (as at 8 October 2026) only 19 of the 27 Member States have EmpCo laws. Click on a country or use the dropdown menu to see whether and how it has put EmpCo laws in place.

About EmpCo

EmpCo amends the Unfair Commercial Practices Directive and the Consumer Rights Directive and applies to business-to-consumer practices. It bans generic environmental claims (eg, "green" or "eco-friendly"), unless the trader can show recognized excellent environmental performance. It also bans certain climate-related claims if they are based on offsetting, and bans the use of sustainability labels that are not based on a third-party certification scheme or set by a public authority. Claims about future environmental performance (eg, "net zero by 2030") are only permitted if they are backed by a detailed implementation plan, which is regularly verified by an independent third-party expert. EmpCo also bans practices linked to the early obsolescence of consumer products, and requires sellers to give consumers information on guarantees, software updates and repairability.

All businesses which target consumers in EU and/or EEA countries in their marketing and/or sales, the national EmpCo laws applicable in each of the countries where those consumers are targeted.

Where countries stand

In May 2026, the European Commission launched infringement proceedings against 20 Member States for failing to communicate the complete transposition of the directive. As at 5 October 2026, 19 of the 27 Member States have measures in force, one has passed legislation that is awaiting signature, five have drafts or bills in progress, and two have not yet put forward a measure. The directive has not yet been incorporated into the EEA Agreement, but our tracker addresses the status in Norway, Iceland and Liechtenstein for completeness.

Where a country does not yet have a national EmpCo law, the route to enforcement action is less clear, but non-compliant traders still risk consequences. For example, EU law would direct existing national rules on misleading consumer practices to be interpreted in line with the directive, increasing the risk of challenge to the practices that EmpCo targets.

Where national laws differ

Although the directive imposes uniform requirements on Member States, national laws can differ. A few countries apply the rules earlier or later than 27 September 2026. Some laws in force (or in draft) include transitional exemptions for goods already produced or on the market, despite the directive not providing for this. There are also variations in definitions, the description of the independent verifier of future claims, and the applicable penalties.  Importantly, laws in a small number of jurisdictions appear to apply specific aspects of EmpCo to business-to-business conduct, despite the directive only applying to the consumer context.

Click on a country or use the dropdown menu for its transposition status, latest developments, links to the national instrument and EUR-Lex, in force and application dates, and a brief indication of where its national law appears to go beyond the directive (gold-plating) or delays or narrows it. Each panel also shows how the national text was reviewed. Our client guide has a page for each country.

Tracker information

• Lawyer-checked: The only content reviewed by lawyers is the transposition status in each country, which was checked against primary sources, using English translations where needed.
• AI-produced: All other text was produced by AI, based only on the underlying legislation, draft legislation and consultation publications, as relevant. Asterisks (*) have been used as a non-exhaustive indication of material that is AI-produced. Every AI-produced entry must be verified against the primary national text by readers.

All information on this page and contained in the tracker is provided for general information only, and is not legal advice.