Since 27 September 2026, European Union Member States must apply Directive 2024/825, known as EmpCo, which regulates environmental claims and sustainability labels. In France, however, transposition is running late: the current national framework continues to apply until the new provisions have been incorporated into French law.
Even so, it is better to get ahead of it now. For a brand or retailer operating in several European countries, the challenge is the same everywhere: every environmental claim must be specific, substantiated and linked to the right product. That means controlling the data behind it.
Key takeaways
- Vague terms are no longer enough: “eco-friendly” or “environmentally friendly” cannot be defended without recognised excellent environmental performance relevant to the claim.
- A clarification must appear in the same place as the claim, in clear and prominent terms.
- A claim is more than a sentence: a pictogram, a label or a product-range name can constitute one.
- The real challenge is operational: knowing which information is validated, for which product reference, and where it is published.
What the directive considers misleading
This tightening responds to a long-standing finding. According to a European Commission study published in 2020, 53.3% of the environmental claims examined were vague, misleading or unfounded, and 40% had no supporting evidence.
The directive now lists several practices among those that may be considered misleading:
- generic claims (“eco-friendly”, “environmentally friendly”, “biodegradable”) without recognised excellent environmental performance relevant to the claim;
- a partial benefit presented as a global one, where it concerns only one aspect of the product or the business;
- labels without a solid basis, which are not based on a certification scheme or have not been established by a public authority;
- neutrality claims (for example “carbon neutral”) based on emissions offsetting.
Any clarification given for a generic claim must appear in clear and prominent terms on the same medium. “Eco-friendly packaging” remains a general phrase; the fact that the energy used to manufacture it comes entirely from renewable sources is specific information, to be stated on the packaging, in the advertising or on the same online sales interface.
The scope is broad: text, image, symbol or label, but also brand, company or product name whenever it suggests an environmental benefit. A green leaf, a badge or a range name can therefore be analysed. Following a coordinated action by European consumer protection authorities launched in April 2022, Zalando thus committed to removing certain environmental flags and pictograms in favour of more explicit product characteristics.
Why the real challenge lies at product catalogue level
Validating a claim when a range is launched is one thing; keeping it accurate over time is another. Modified packaging, a change of supplier, an expired certification or a translation left on the old version are enough to create a gap with the product actually sold, all the more so because a single reference circulates in several languages, at several retailers, with different data models.
The hidden risk: outdated information still online
Once sent to retailers, marketplaces, e-commerce sites or apps, the information is picked up in environments that have their own formats and update cycles. Data corrected at source can therefore remain unchanged elsewhere: an old description at a retailer, an outdated attribute on a marketplace, a legacy visual still associated with the product.
Existing stock gets no automatic transition period. In June 2026, the CPC network authorities adopted a common position to harmonise their checks on products and packaging manufactured, ordered, distributed or placed on shelves before 27 September. Companies are expected to make the adaptations they can reasonably undertake, and the authorities may take a phased approach where there are real and specific transition difficulties.
In practice, the same claim can coexist on packaging that has already been printed, in a corrected PIM record, on the brand’s website and in several retailer catalogues. Changing one of these occurrences does not change the others.
The role of the PIM: finding the right information, on the right reference
A PIM (Product Information Management) system is the central repository for product information. It does not rule on whether a claim is lawful, but it structures the information, adapts it by language or market and organises its validation among the teams concerned (legal, CSR, marketing) before it is published, keeping a record of each decision. It thus makes it possible to identify the validated information and the references it applies to.
An up-to-date PIM combined with a Digital Shelf Analytics solution makes a particularly powerful duo for compliance:
- The PIM, the source of truth. It centralises validated information, reference by reference, by language and by market, then distributes it to sales channels through a syndication solution.
- Digital Shelf Analytics, the on-the-ground check. It compares the expected information with what is actually published on digital channels and highlights discrepancies: old description, outdated attribute, legacy visual.
Together, they make it possible to identify incorrect information across all digital channels, correct it in the PIM, then republish it to ensure compliant information.
Where to start: four actions to launch
On a catalogue of several thousand references, it is better to proceed in stages.
- This week: identify at-risk claims. List the generic mentions (“eco-friendly”, “green”), pictograms and labels on your product sheets, packaging and websites. Start with your best-selling ranges.
- This month: link each claim to its evidence and its reference. Supporting document, certification, scope (whole product or a single aspect) and end-of-validity date must be attached to the relevant product record, by language and by market.
- Next: set a validation rule. Decide who validates a claim before publication (legal, CSR, marketing) and who withdraws it when the evidence expires.
- Ongoing: check what is actually published. Regularly compare your repository with what appears at your retailers and on marketplaces. For stock already produced, keep a record of the adaptations undertaken: the authorities expect reasonable efforts.
Product data quality does not determine the legal compliance of an environmental claim. It does, however, determine the ability to apply a validated correction to the right reference, in the right version and across all sales channels.
