11 December 2025
newsletter
austria
Greenwashing: European Commission FAQs published
As the EU has been working for years to combat greenwashing at the legislative level, the deadline for national transposition (27 March 2026) and subsequent application (27 September 2026) of the new Directive (EU) 2024/825 on the empowerment of consumers ("EmpCo Directive" or "ECGT Directive") is approaching fast. And while advertisers are well advised to design their environmental advertising with foresight, many uncertainties remain as to when and how advertising campaigns and the use of logos will be affected.
1 New FAQs
To help navigate the new regime governing environmental advertising, the EU Commission has published answers to frequently asked questions from stakeholders related to the EmpCo Directive. The FAQs address topics such as:
- promoting a product as "carbon neutral";
- referring to future environmental targets;
- making claims about "social characteristics" such as fair working conditions;
- brand or product names containing "green" buzzwords; and
- using green images such as trees or waterdrops (e.g. on packaging or in advertising).
2 What advertisers should know and work on now
These Q&As serve not only as non-binding guidance but also as a reminder for advertisers to identify potential risks in their advertising and communication materials. Given typical lead-times for campaign planning, advertisers should make necessary adjustments in good time before the transposed legislation enters into force in September 2026.
Click here to find out more about how brands may be affected under the new EmpCo Directive.
author: Antonia Hirsch
Antonia
Hirsch
Associate
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