Europe’s anti-greenwashing rules start applying in five weeks. The label has been designed down to the millimetre and the Pantone reference. Twenty of the twenty-seven countries that have to enforce them had not written them into national law by the spring — and it is the seller who carries that gap, not the regulator.
On 27 September 2026 the EU’s Empowering Consumers for the Green Transition Directive — EmpCo, Directive (EU) 2024/825 — starts to apply. From that day a shop selling goods to consumers has to display a standard notice explaining the legal guarantee. Words like “eco-friendly” and “climate neutral” become unlawful unless the seller can show what is behind them. Product pages have to say whether spare parts exist, for how long, and how long the software will be updated.
Packaging law went the other way round. The PPWR is a regulation: it applied the same way in all twenty-seven countries from day one, whether or not anyone passed anything locally. EmpCo is a directive. Before it can do anything it has to be copied into twenty-seven national laws, by twenty-seven parliaments, on twenty-seven timetables. That single drafting choice is why the rest of this article exists.
Nobody fought it, either. Parliament passed the directive on 17 January 2024 by 593 votes to 21, with 14 abstentions — about as close to unanimous as the chamber gets. This is not a contested law being resisted by reluctant governments. It is an uncontroversial law that most governments simply did not get round to.
The part that never got harmonised
Member states had until 27 March 2026 to put EmpCo into national law. Twenty of them missed it. On 28 May 2026 the Commission sent letters of formal notice to Belgium, Bulgaria, Czechia, Estonia, Greece, Spain, France, Croatia, Cyprus, Latvia, Luxembourg, Hungary, Malta, the Netherlands, Austria, Poland, Portugal, Slovenia, Finland and Sweden — the opening move of an infringement procedure. A handful have moved since. Most of the list has not.
The countries that did finish look like this, and so does everybody else:
| Country | National law | Status |
| Germany | Third Act amending the UWG | published 19 Feb 2026 |
| Italy | Legislative Decree 30/2026 | published 9 Mar 2026 |
| Ireland | S.I. No. 124 of 2026 | in place |
| Sweden | drafted | planned for 1 Jan 2027 |
| 20 member states | letters of formal notice | sent 28 May 2026 |
Sweden is the one worth sitting with. Its national implementation is planned to enter into force on 1 January 2027 — three months and change after the European rule it implements starts to apply. For a full quarter, a Swedish seller is subject to a European obligation with no domestic law behind it, and a Swedish consumer has a right that the national statute book has not yet heard of.
The Commission gave the twenty countries two months to reply. The application date did not move. So the rule arrives on 27 September in a legal landscape where a majority of member states are somewhere between a draft bill and a formal notice, and where the seller is expected to be ready anyway.
The poster is the easy part
The two labels are genuinely, impressively finished. Implementing Regulation (EU) 2025/1960, adopted on 25 September 2025, fixes them completely: the guarantee notice at minimum A4, colour or black and white in a shop, RGB online, with a QR code to the Your Europe portal. The voluntary durability label — titled GARAN — is specified at a minimum of 95 by 100 millimetres, in Pantone Reflex Blue and Yellow, with a tick, a calendar symbol, the guaranteed years, the producer, the model, and rules for how it may be nested behind a click online. A producer may use it only where its guarantee covers the whole good, runs longer than two years, and costs the buyer nothing.
Print it, hang it near the till, put it on the site. An afternoon’s work.
The expensive part is the part nobody photographs. Every environmental claim on every pack, product page and advertisement has to be audited: generic wording, self-made eco-badges, offset-based neutrality claims, forward promises like “climate neutral by 2030” that now need publicly available commitments, measurable targets, an implementation plan and independent verification behind them. And for each product, a seller has to gather and publish spare-parts availability and the minimum period they will be supplied, whether repair instructions exist and how to get them, any repair restrictions such as authorised-workshop conditions or software locks, and, for anything with digital elements, how long updates will come.
None of that data belongs to the retailer. It sits with suppliers, who are under no equivalent deadline to hand it over, and it has to be collected product by product.
The cost lands per product, not per sale
There is no price list for this yet. Cross-border packaging compliance grew an entire industry with published per-country tariffs; EmpCo has not, which makes the cost easy to miss until it arrives. But the shape of it is clear enough from what the work is.
It is a fixed cost per product line and a fixed cost per legal regime, and neither scales with how much you sell. A brand with twelve products does the supplier chase twelve times. A brand with four thousand does it four thousand times, with a compliance team and a system, and the per-unit cost disappears into the volume. That is the same arithmetic that has been pushing small sellers out of cross-border packaging obligations for the past year, arriving from a different direction.
The legal side compounds it. A claim has to survive not one regime but every national one the seller trades into, and those regimes already differ. Germany transposed one-to-one with no gold-plating but applies parts of the regime to business-to-business dealings as well. Austria runs its version through its 1984 unfair competition act, which already carries live case law on carbon-neutrality claims. Others have not published a text at all. A single line of packaging copy now has to be defensible across a set of national laws that a seller cannot finish reading, because several of them have not been written.
Brussels wrote the strict version and walked away from it
It was not supposed to work like this. The EU’s serious attempt at green claims was a separate instrument, the Green Claims Directive, which would have required explicit environmental claims to be independently verified before use — a single substantiation standard, checked in advance, the same everywhere.
On 20 June 2025 the Commission announced its intention to withdraw it. The third trilogue was cancelled days later. The withdrawal was then never actually completed: Parliament’s legislative tracker still lists the file as blocked, and it turned up as pending in the Commission’s 2026 Work Programme. It is not dead. It is not alive. It sits there.
What shipped instead does much of the same work through the existing unfair-competition rulebook — which is to say, through twenty-seven national enforcement systems with twenty-seven sets of procedure, case law and penalties. The stricter proposal would have been harder to comply with and far easier to understand. Given a choice between one demanding standard and twenty-seven vague ones, Europe has ended up with the twenty-seven, and by accident rather than decision.
The one number that would have helped is missing
The most useful thing in the whole package, from a shopper’s point of view, is the repairability score: a single figure letting you compare two machines on whether they can be fixed. EmpCo duly requires it to be shown — where a harmonised EU score exists for that product category.
One exists for smartphones and tablets, graded A to E, in force since 20 June 2025. That is the list. For a kettle, a coffee machine, a washing machine, a chair, a pair of boots or a jacket, there is no harmonised score, so there is nothing to display. The obligation is real and almost entirely empty, and it will stay that way until the ecodesign work grinds through the remaining product groups.
So on 27 September the consumer gets a poster about a guarantee they already had, and a durability label the producer may decline to use, and for nearly everything on the shelf no repairability score at all. The genuinely valuable disclosures — spare parts, update windows, repair restrictions — are there, but as prose buried on a product page rather than as a number anyone can compare.
Who can absorb an uncertain rule
The penalty everyone quotes is the 4% one: for widespread infringements with a Union dimension, member states must provide for penalties reaching at least 4% of annual turnover in the affected countries. That is aimed squarely at large firms, and it is fine that it exists.
It is not what a small seller will meet. The everyday exposure under EmpCo is an injunction brought by a competitor or a consumer association — in Germany, the standard machinery of the UWG — and that machinery attaches to whoever is easiest and cheapest to pursue. A large brand answers it with a legal team and one review cycle. A small one answers it by paying for advice it had not budgeted for, or by guessing.
Guessing has an obvious safe direction, and this is the part that should worry the people who wrote the law. Faced with a rule whose national text you cannot read yet, the risk-free move is to say nothing at all: strip the environmental language off the label and sell the product mute. The large producer with a certification budget keeps making its claims, because it can substantiate them on paper. The small maker who actually does the greener thing, but has no third-party certificate to point at, stops mentioning it. A rule written to stop false green claims can end up thinning out the true ones, and leaving the field to whoever can afford the paperwork.
That is not a reason to keep letting anyone print “eco-friendly” on anything. The 2020 screening that started all this found 53% of environmental claims vague, misleading or unfounded, and 40% with no evidence at all; that was untenable and it needed fixing. It is a reason to notice that the fix has been shipped without the single verification standard that would have made it usable, and into a legal landscape that is missing in most of the countries it applies to.
The deadline that was met
What is striking about EmpCo is not that it is late. Nothing about it is late. The directive was adopted on time, almost unanimously. The implementing regulation that fixes the artwork landed a full year before it was needed, complete with millimetre dimensions and Pantone references. The one deadline that mattered — the one twenty national governments had — is the one that slipped, and it slipped without moving the date on which everybody else has to comply.
So the poster goes up on 27 September, precisely specified, in shops in countries that have not yet passed the law it refers to. It will tell customers about a right they already had, next to products carrying no repairability score, priced by sellers who cannot yet read the rules they are being held to. Europe finished the sticker and left the law for later.
Sources
Directive (EU) 2024/825 (Empowering Consumers for the Green Transition) — EUR-Lex; European Parliament plenary vote of 17 January 2024, 593-21-14.
Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025 on the design and content of the harmonised notice on the legal guarantee of conformity and the harmonised label for the commercial guarantee of durability.
European Commission, letters of formal notice of 28 May 2026 to twenty member states for failure to transpose Directive (EU) 2024/825 by 27 March 2026.
National transposition status: Germany, Third Act amending the UWG, published 19 February 2026; Italy, Legislative Decree 30/2026, published 9 March 2026; Ireland, S.I. No. 124 of 2026; Sweden, entry into force planned 1 January 2027. CMS and ClimatePartner implementation trackers, 2026.
European Parliament Legislative Train, “Substantiating green claims” — Commission announcement of intention to withdraw, 20 June 2025; third trilogue cancelled 23 June 2025; file listed as blocked and pending in the 2026 Commission Work Programme.
European Commission screening of environmental claims, 2020 — 53% vague, misleading or unfounded; 40% unsubstantiated.
Harmonised repairability scoring for smartphones and tablets, grades A to E, applicable from 20 June 2025 under the ecodesign framework.
Directive (EU) 2019/771 on the sale of goods — scope of the legal guarantee of conformity; national carve-outs for food and everyday household items.
