Short answer: Since 27 September 2026, the Empowering Consumers Directive (EmpCo, Directive (EU) 2024/825) applies across the EU. Generic environmental claims such as "eco-friendly" or "climate-friendly" are now only allowed if you can demonstrate recognised excellent environmental performance. Sustainability labels need a certification scheme or a public authority behind them, and "climate neutral" based on offsetting is banned outright. Legally, this has nothing to do with the Digital Product Passport, but both need verifiable product data. If your data is already organised for the DPP, you have a good foundation for your claims, though it doesn't replace the actual substantiation.

Which green claims are banned since 27 September 2026?

The directive adds new items to the EU blacklist of unfair commercial practices. These are always banned, whether or not a consumer was actually misled:

Claims about future performance, such as "net zero by 2035", are still allowed, but only with a detailed, public implementation plan and regular checks by an independent expert.

Pre-contractual information changes too: traders have to tell customers about durability, commercial guarantees and repair, using the harmonised notice and label from Implementing Regulation (EU) 2025/1960.

Who enforces the green claims rules?

EmpCo works through national consumer protection law, in Germany through the UWG. So there are two ways it gets enforced: consumer protection authorities, with fines that can reach 4% of annual turnover in the member states concerned for widespread infringements, and competitors and consumer associations, who can seek injunctions. In Germany and Austria, competitor cease-and-desist letters are the more likely first contact. Transposition was due on 27 March 2026 and has been uneven, so check your national law.

What do green claims have to do with the Digital Product Passport?

Legally, the two are unrelated. EmpCo is consumer law, while the DPP comes from product law (the Batteries Regulation and ESPR), and each has its own obligations and timeline.

The data behind them overlaps heavily, though. A claim such as "contains 50% recycled polyester" needs a number, a calculation basis and a source. The textile DPP is expected to ask for the same kind of data (see our textile DPP article). A durability claim needs test data, which ESPR ecodesign requirements ask for as well. The battery passport even puts recycled content and carbon footprint values in its public layer.

If your product data is stored as clean attributes, with the source of each value documented, you can support a specific claim quickly. If it lives in marketing copy and PDFs, you'll struggle with EmpCo now and with the DPP later.

Does a DPP make green claims compliant?

Having a passport doesn't make a claim legal. Keep these limits in mind:

• A DPP publishes data but doesn't verify it. Your claim still needs evidence that holds up.
• A DPP is not a sustainability label. Putting a "DPP" badge on a product and implying it means "sustainable" would be the kind of claim EmpCo bans.
• Most product groups have no DPP obligation yet. Until their delegated acts apply, the DPP is a voluntary tool for them, see our DPP timeline.

How to check your green claims now

1. Collect every environmental claim you use: packaging, product pages, ads, social media, B2B catalogues.
2. Remove generic claims and self-made labels, or replace them with specific, measurable statements.
3. For each remaining claim, record the data point behind it, its source and who owns it.
4. Move those data points into your PIM as structured attributes instead of free text.
5. Link the product page or QR code to the underlying data, so customers can check it themselves.

Step 4 is also the first step of any DPP project, and the same attributes feed ESPR, battery and packaging obligations, as we show in one product data model for all EU rules. We explain how it works with Akeneo and other PIM systems. And if you're wondering how DPP data can pay for itself beyond compliance, see what Forrester's 2026 report says.

"A product passport doesn't make a marketing claim legal. But if the passport and the packaging draw on the same maintained data, the numbers are far less likely to contradict each other, and that's where a lot of claims go wrong today."

Sebastian Eberhardt, Director Business Development, dpp.cloud

How dpp.cloud fits

dpp.cloud takes structured product data from your PIM and publishes it behind a QR code per product. For EmpCo that gives you a public place to disclose the specific numbers behind your claims. The evidence itself (calculations, test reports, chain-of-custody records, certificates) stays in your files. Once your product group falls under ESPR, you can build the passport on top of it. Book a strategy session if you want to see what that looks like with your data. We can't give legal advice on individual claims, so talk to your legal team about those.

Sources

• Directive (EU) 2024/825 (Empowering Consumers for the Green Transition), EUR-Lex: eur-lex.europa.eu/eli/dir/2024/825/oj
• European Commission, FAQ on the Empowering Consumers Directive: commission.europa.eu
• Regulation (EU) 2024/1781 (ESPR), EUR-Lex: eur-lex.europa.eu/eli/reg/2024/1781/oj