EU EmpCo rules activate a 4% turnover risk for unsupported green claims

On September 27, the EU’s Empowering Consumers for the Green Transition rules began applying, as Reuters explained in a September 18 analysis of the new greenwashing regime. The framework restricts generic claims such as “green” or “environmentally friendly,” limits sustainability labels to qualifying certification schemes and prevents companies from using carbon offsets to support product-level climate-neutral claims; Reuters reported potential penalties of up to 4% of annual turnover. Companies selling into the EU should now treat website copy, packaging, reports and product labels as controlled legal statements supported by accessible evidence, not as separate marketing assets. Counsel should also map which claims depend on operational emissions reductions, third-party certification or supplier data because each creates a different substantiation and record-retention requirement.