EmpCo: How to Substantiate Sustainability Claims in Practice
Sep 27, 2026SustainabilityBusinesses need to align their claims with appropriate and reliable evidence
From 27 September 2026, EmpCo introduces new requirements for consumer-facing environmental and sustainability communications. Businesses need to take a closer look at their claims and the evidence behind them.
EmpCo introduces stricter requirements for environmental and sustainability claims directed at consumers in the EU, Iceland, Liechtenstein and Norway. Businesses must consider not only the wording of a claim, but also the overall impression it creates.
Some types of claims require particular attention. These include:
- Generic environmental claims
- Climate neutrality claims based on offsetting
- Voluntary sustainability labels
- Future environmental performance claims
- Claims that overstate the scope of an environmental benefit
- Environmental benefits that simply reflect legal requirements
- Irrelevant or self-evident benefits
- Claims related to durability, repairability and software updates
For businesses, this means reviewing claims alongside the supporting evidence. Supporting evidence should be appropriate to the wording and scope of the claim.
Substantiation Moves to the Foreground
EmpCo does not prescribe one universal approach to substantiating every claim. Depending on the type, wording and scope of the claim, businesses need to consider whether the supporting evidence is appropriate, reliable and transparently documented. In practice, this involves three key questions.
Claims about entire products require different evidence from specific statements about recycled content, energy use, or carbon footprints. For example, evidence relating only to packaging cannot support a claim about the environmental performance of the product as a whole.
Depending on the claim, relevant evidence may include carbon footprints, life-cycle assessments, product or material testing, traceability information, documented performance, or results from validation, verification, certification, or audits. The selected evidence must reliably support the statement being made and be documented transparently.
Substantiation should be considered when a claim is developed, not only shortly before publication. This requires marketing, sustainability, product and legal functions to work together so that the claim and its supporting evidence are aligned from the outset.
Depending on the type of claim and the supporting evidence required, an independent assessment may form part of the substantiation process.
The Role of Independent Assessment
Independent assessment can contribute to the evidence base supporting environmental and sustainability claims. Depending on the subject matter and scope of the claim, testing, inspection, or certification can help evaluate product characteristics, environmental performance, calculation methods, traceability, and compliance with defined criteria.
EmpCo introduces specific requirements for independent third-party monitoring of certain sustainability label schemes and for the verification of claims concerning future environmental performance. In other cases, independent assessment can strengthen the credibility and traceability of the evidence supporting a claim.
How Businesses Can Respond
For many organizations, the practical starting point is to review the environmental and sustainability claims already in use and the evidence behind them. This can help identify which claims require closer attention under EmpCo and where internal review processes should be strengthened.
Claims should be evaluated from marketing and substantiation perspectives, as well as in terms of traceability and transparency. Clear responsibilities and closer coordination between marketing, sustainability, product and legal functions can help ensure that claims and supporting evidence are aligned from the outset.