What EmpCo Means for Voluntary Sustainability Schemes

The EU has spent years strengthening environmental claims regulations. The next challenge is ensuring their consistency across the Single Market.

From 27 September 2026, the Empowering Consumers for the Green Transition Directive (EmpCo) will enter into force, introducing new requirements for how businesses communicate environmental characteristics to consumers and how sustainability labels can be displayed. The Directive aims to make environmental information more reliable, specific, and meaningful, while preventing consumers from being misled by vague or unsupported claims.

For organisations such as the Marine Stewardship Council (MSC), which operates a voluntary certification program and ecolabel based on independently assessed standards, this has been more than a change in marketing language. It has required a careful review of how certification is communicated to consumers, while raising broader questions about the role of credible voluntary sustainability schemes within the EU’s green transition framework.

MSC has been engaged in this policy discussion since the early stages of the EU’s work on green claims. Alongside other sustainability standards and ecolabels, and through collaboration with ISEAL – the global membership body for credible sustainability standards – we advocated for the regulatory framework to distinguish between unsupported environmental marketing and claims underpinned by credible certification systems.

That distinction is reflected in the final Directive. EmpCo prohibits the display of sustainability labels that are not based on a certification scheme or established by public authorities. It also sets requirements for certification schemes, including transparency, stakeholder participation, and independent monitoring. For credible voluntary sustainability schemes, this is an important development: independent verification and accountability are recognised within the EU’s legal framework for sustainability labels, rather than simply serving as mechanisms for building consumer and market confidence.

This does not mean that certified organisations can simply continue communicating in the same way. The Directive also changes the wider environment in which environmental claims are made. Generic environmental claims such as “green” or “eco” are subject to stricter conditions, while claims relating to sustainability or responsibility require particular care because they can encompass characteristics beyond environmental performance.

Generic environmental claims such as “green” or “eco” are subject to stricter conditions, while claims relating to sustainability or responsibility require particular care.

For MSC, the regulatory change translated into practical exercise across markets. We reviewed and revised the claims accompanying our ecolabel so that they more clearly explain what certification means and what the label covers.

The objective was not simply to meet the September 2026 application date. It was also to ensure that the claims consumers encounter are specific, understandable, and defensible, while giving businesses operating across multiple markets a consistent basis for communicating certification. For a global voluntary certification scheme, consistency itself is an important part of making compliance workable.

And this is where the next challenge emerges: implementation.

EmpCo creates a common EU framework, but its practical application depends on national transposition, guidance, and enforcement. Member States are progressing at different speeds, while businesses are beginning to engage with national authorities and other enforcement bodies on how the new requirements should be applied in practice.

For companies operating across several Member States, this can create uncertainty. The same underlying evidence, wording, or substantiation approach may generate different questions in different markets. This is not necessarily a contradiction in the Directive itself; rather, it reflects the challenge of translating a common European framework into practical enforcement across 27 national systems.

For voluntary sustainability schemes operating internationally, that challenge is particularly significant. Certification systems are designed to provide a consistent framework across markets. If regulatory expectations surrounding the communication of that certification vary substantially between jurisdictions, organisations, and businesses using their labels can face additional compliance complexity, even where the underlying environmental evidence and certification requirements remain unchanged.

None of this diminishes the case for EmpCo. Consumers should be able to distinguish credible environmental information from vague or unsupported claims, while businesses that invest in genuine environmental performance should be able to compete on a more level playing field. These are objectives that credible certification schemes have supported for many years.

The priority now should be to make the framework work consistently in practice. Greater coordination between national competent authorities, alongside clear EU-level guidance on how requirements for documentation and substantiation should be interpreted, would benefit regulators, businesses, certification schemes, and ultimately, consumers.

The implementation of EmpCo is therefore not the end of the green claims debate. It is the beginning of a new phase: moving from establishing common rules to ensuring that they can be applied consistently across the Single Market.

The implementation of EmpCo is therefore not the end of the green claims debate. It is the beginning of a new phase: moving from establishing common rules to ensuring that they can be applied consistently across the Single Market. MSC will continue to work with companies and stakeholders to ensure that our certification and consumer-facing claims remain clear, credible, and fit for purpose as the regulatory landscape evolves.