To continue using such claims, food retailers and brands will need proof of “excellent recognised environmental performance,” for example:

• The official EU Ecolabel
• National or regional ISO 14024 Type I ecolabels
• If the claim cannot be proven, it cannot be communicated.

EmpCo must be transposed into national laws by March 2026 and will apply from September 2026. That leaves less than one year for food retailers and brands to adapt.

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Checklist for EmpCo Readiness

This checklist outlines the key steps to ensure sustainability claims meet EmCo requirements.

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1. Audit all claims

Review packaging, websites and advertising. Flag uses of “eco”, “green”, “climate friendly”, “sustainable”, “biodegradable”, “biobased”, “responsible”, “conscious”, etc. These are high-risk under EmpCo because they are too vague and can mislead consumers.

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2. Remove or replace vague claims

If a claim is too broad and you cannot back it with evidence, remove it. Where possible, replace it with a specific and measurable statement. For example, instead of eco-friendly packaging, say packaging made with 100 percent recycled PET, verified by [certifier]. The key is precision: every claim should describe a concrete fact that can be verified.

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3. Substantiate everything

Keep life-cycle assessments, supplier documentation, laboratory test results, and third-party certificates on file. Set up a central database or compliance folder so your teams can quickly access proof if regulators or partners ask for it. Remember: if you cannot prove it, you cannot say it.

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5. Handle future commitments carefully

Many brands communicate long-term goals such as net zero by 2030. Under EmpCo, such claims are only allowed if supported by a detailed roadmap. This must include clear milestones, budget allocations, and independent monitoring. Make sure progress reports are published and accessible. Without these elements, future-oriented claims will be considered misleading.

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4. Use recognised certification schemes

Under EmpCo, any sustainability label shown to consumers must be based on a certification system established by a public authority or run by an independent third party that meets EmpCo’s criteria. Not all existing ecolabels will qualify. The scheme must be open to all businesses on transparent, fair and non-discriminatory terms, follow clear standards, include procedures for non-compliance, and be subject to independent, accredited monitoring. In-house logos or proprietary “eco badges” will not suffice. The ESFC plans to develop such a scheme for F&B, and inoqo intends to participate as an accredited independent verifier once available.

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6. Train your teams

Marketing, product and sustainability staff must understand what can and cannot be said under EmpCo. Provide training sessions and create simple “do’s and don’ts” guides. For example, marketers should know that climate neutral is no longer acceptable if based on offsets, and product managers should understand the type of evidence required to support material claims.

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7. Plan your transition early

Although EmpCo becomes enforceable in September 2026, waiting until then is risky. Aim to have all claims and labels compliant by the end of 2025. This allows time to phase out old packaging, align communication strategies, and avoid costly last-minute changes.

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How inoqo Can Support

inoqo provides product-level impact data that turns generic claims into precise statements. We work with retailers and brands to align claims with recognised certification schemes and prepare for third-party verification. By September 2026, our customers will be ready with claims that are accurate, transparent and fully compliant. To learn how inoqo can support your organisation, contact hello@inoqo.com.

Also, join our webinar on 9 October at 11:00 CEST, “Empowering Consumers Directive: Sustainability Claims in the F&B Sector” Martin Ranninger (V-Label), Markus Linder (inoqo), and Dr. Constantin Eikel (Bird & Bird) will show how to craft sustainability claims that resonate, comply and drive impact by connecting product-impact data to consumer-facing labels, clarifying EmpCo requirements, and sharing practical do’s and don’ts to avoid greenwashing and build trust.

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