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EmpCo in Luxembourg: What the New EU Green Claims Rules Mean for Communications
From 27 September 2026, new EU consumer-protection rules on environmental and sustainability claims apply in Luxembourg. Here is what it means for businesses, communication teams, public institutions and social-impact organisations — and what to review before publishing your next claim.
Sustainability has become part of everyday communication. Companies describe products as green, sustainable or climate-friendly. Organisations communicate their social impact. Public institutions report on environmental initiatives. Social enterprises explain the change they aim to create.
From 27 September 2026, the rules around some of these claims become more explicit in Luxembourg.
The change comes from Directive (EU) 2024/825, commonly referred to as the Empowering Consumers for the Green Transition Directive, or EmpCo. It amends existing EU consumer-protection legislation to strengthen protection against misleading environmental and sustainability communication.
Luxembourg transposed the Directive through the Law of 9 June 2026, which modifies the Code de la consommation. The Luxembourg law enters into force on 27 September 2026.
For communication and marketing teams, this creates a useful moment to ask a broader question:
Can we actually support what we are saying?
What is EmpCo?
EmpCo is part of the EU's wider effort to help consumers make better-informed purchasing decisions and to tackle misleading sustainability communication and greenwashing. It amends two existing EU directives: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU).
Among other changes, the Directive introduces specific definitions and rules concerning environmental claims, generic environmental claims and sustainability labels, while strengthening existing rules on misleading commercial practices.
This means that communication is relevant far beyond a sustainability report. A claim can appear in advertising, on packaging, on a website or product page, in a brand message, or through visual and symbolic elements. Under the Directive, even brand or product names can constitute environmental claims when they communicate or imply an environmental benefit in a commercial context.
So what changes from 27 September 2026?
Misleading commercial practices were already regulated in the EU, and companies and financial market participants have faced increasing scrutiny over greenwashing and misleading sustainability claims.
One important change concerns generic environmental claims.
Terms such as green, environmentally friendly, eco-friendly or climate friendly can fall into this category. EmpCo restricts generic environmental claims where the relevant recognised performance cannot be demonstrated. Providing a clear and prominent specification on the same medium can also change whether a statement is considered a generic claim.
The Directive also addresses several other practices.
Sustainability labels. Under the new rules, displaying a sustainability label that is not based on a certification scheme or established by a public authority is added to the list of commercial practices considered unfair in all circumstances.
Carbon-offsetting claims. Claims that a product has a neutral, reduced or positive greenhouse-gas impact when this is based on offsetting emissions outside the product's value chain are prohibited. The Directive gives examples such as climate neutral, CO₂ neutral certified and climate compensated.
Future environmental claims. Claims about future environmental performance need clear, objective, publicly available and verifiable commitments supported by a detailed and realistic implementation plan with measurable, time-bound targets and regular independent third-party verification.
The amended rules explicitly include environmental and social characteristics among the characteristics about which misleading information can affect consumers. The Directive's recitals mention areas such as working conditions, human rights, equal opportunities, gender equality, inclusion, diversity, contributions to social initiatives and ethical commitments.
That makes EmpCo relevant to conversations about both greenwashing and misleading social-impact communication.
Who is directly affected?
At its core, EmpCo is consumer-protection legislation.
Its main legal focus is therefore on traders and commercial practices involving consumers. For Luxembourg businesses communicating environmental or sustainability benefits, the changes are particularly important.
Retail, hospitality, mobility, consumer services, financial products and services, e-commerce and other B2C sectors should therefore review consumer-facing sustainability communication carefully.
But direct legal applicability and communication relevance are not necessarily the same thing.
The direction established by EmpCo matters to a wider group of organisations.
Why should B2B companies care?
EmpCo is consumer-protection legislation, but the principle behind it is much broader: if an organisation makes an environmental or social claim, it should be clear, accurate and supported by evidence.
For B2B companies, credible sustainability communication matters beyond consumer marketing. The same claims can be seen by clients, partners, employees, regulators, lenders and investors — and sustainability information can form part of investment and other stakeholder decisions.
Also, a statement developed for an ESG report may later become a website headline, a sales message, a LinkedIn post or part of a corporate presentation. What begins as B2B communication can eventually reach consumers.
This is why claim governance is good communication practice for any organisation, regardless of sector: know what you are claiming, what evidence supports it, where the claim appears, and who is responsible for approving it.
EmpCo raises the legal bar in consumer communication. But clear, truthful, and evidence-based communication is a stakeholder trust issue for every business.
Why should social impact organizations care?
For Sociétés d'Impact Sociétal (SIS), NGOs and other impact-driven organisations, environmental communication is only part of the picture.
These organisations frequently communicate social claims: creating impact, supporting vulnerable communities, promoting inclusion, empowering people, creating equal opportunities.
Some may be entirely legitimate descriptions of the organisation's work. But there is still an important difference between describing an activity, an output, an outcome and a broader impact.
For example:
“We delivered six employment workshops.”
is not the same claim as:
“250 people participated in our employment programme.”
And neither automatically demonstrates:
“Our programme improved employment opportunities for vulnerable people.”
Not every social-impact statement automatically falls under EmpCo. The audience, context and nature of the communication matter. But the Directive reinforces a wider principle that is highly relevant to impact communication: the strength of the message should be proportionate to what can actually be supported.
What about public institutions and communes?
Public institutions and communes should also distinguish between legal applicability and good communication practice.
Public-sector organisations increasingly communicate environmental targets, climate initiatives, circular-economy projects and social programmes to residents, partners, businesses and other stakeholders.
Clarity about what has been achieved, what remains a target, what evidence exists and what role the institution actually played can make that communication more credible and useful.
The principles of specificity, evidence and transparency therefore remain relevant even where a particular communication does not fall directly within the consumer-law framework.
What KOLO is doing about EmpCo
EmpCo is new regulation, but the communication challenge behind it is not new to us. KOLO already works with sustainability claims, social-impact communication and evidence-based messaging. Our existing methodologies and frameworks help organisations distinguish between activities, outputs, outcomes and impact, connect claims to evidence, and build internal processes for reviewing what gets communicated.
With EmpCo, we use this experience to bridge the gap between regulatory requirements and day-to-day communication practice — helping teams translate the new rules into the way claims are actually written, reviewed and published.
We do this through our existing 3D model: Diagnose → Design → Develop.
Diagnose
We identify potentially risky or unclear claims, evidence gaps and weaknesses in the current communication process through our Sustainability & Impact Claims Review.
Design
We help organisations turn the findings into practical claim governance: clearer messaging principles, evidence requirements, responsibilities and internal review processes.
Develop
We build the team's ability to apply these principles in everyday communication through training and practical workshops.
Explore KOLO's 3D methodology →
The challenge is not a list of forbidden words
It would be tempting to reduce EmpCo to a list of words marketing teams should stop using.
The real question is not whether we can use the word sustainable, green, responsible or impact, but what exactly are we saying — and can we show what is behind it?
For communication teams, that is a useful question far beyond 27 September.
Official sources and further reading
Directive (EU) 2024/825 — Empowering Consumers for the Green Transition (EmpCo)
The Directive amending Directives 2005/29/EC and 2011/83/EU. eur-lex.europa.eu
Read Directive (EU) 2024/825 on EUR-Lex
Luxembourg Law of 9 June 2026
The Luxembourg legislation transposing Directive (EU) 2024/825 into the Code de la consommation, entering into force on 27 September 2026. Legilux
Read the Law of 9 June 2026 on Legilux
Luxembourg Code de la consommation
Legilux already lists a consolidated version applicable from 27 September 2026, although that future consolidated text is currently marked as not yet available on the page. Legilux
Code de la consommation on Legilux
Luxembourg Directorate for Consumer Protection — EmpCo guidance
Official Luxembourg guidance explains the implementation timetable and key implications for businesses. mpc.gouvernement.lu