EMPCO Directive: new consumer transparency rules

Publication / 24 September 2026 / Ieva Andersone, Lūcija Strauta, Sabīne Grīsle, Helery Maidlas, Ugnė Gabrielė Motiekaitytė, Guoda Vdovycytė, Vaiva Mašidlauskienė

Overview

On 27 September 2026, new consumer transparency rules will become applicable in the EU.

Directive (EU) 2024/825 (EmpCo Directive), applicable from 27 September 2026, introduces stricter rules targeting greenwashing, misleading sustainability labels and early product obsolescence. Businesses will no longer be able to rely on unsubstantiated generic green claims, uncertified sustainability labels or climate-neutrality claims based solely on carbon offsetting.

Commission Implementing Regulation (EU) 2025/1960 complements the Directive by introducing standardised consumer information tools, including a mandatory EU legal guarantee notice and the new GARAN durability label.

Environmental claims

Generic claims such as “eco-friendly” or “100% eco” will be prohibited unless they are backed by recognised environmental performance certification or accompanied by clear, specific information explaining the environmental benefit in question. Claims based solely on carbon offsetting will be banned outright.

Claims about future environmental performance (e.g. “climate-neutral by 2030”) will only be permitted where supported by a detailed, publicly available implementation plan with measurable targets and independent verification.

Sustainability labels

Displaying a sustainability label will constitute an unfair commercial practice unless the label is based on a certification scheme established by or recognised by a public authority, with objective, publicly accessible criteria and compliance monitoring.

Consumer information tools: EU notice and GARAN label

All traders selling goods to consumers in the EU, both online and offline, must prominently display a standardised EU notice reminding consumers of their legal guarantee rights (which are at least two years). In physical shops, the notice must be displayed in an eye-catching way (e.g. a poster near the checkout); online, it must appear as a general reminder on the trader’s website.

The GARAN label is a harmonised durability label that producers may use when offering consumers a voluntary commercial guarantee of durability exceeding two years, covering the entire product at no additional cost.

Both the GARAN label and the EU notice are subject to detailed design, content and display requirements for physical and online sales channels:

the template of a mandatory EU notice reminding consumers about their legal guarantee rights is available here
the GARAN label template is available here

National implementation

Lithuania

Lithuania has implemented the new EU framework through amendments to two key pieces of legislation.

Amendments to the Law on the Prohibition of Unfair Commercial Practices Against Consumers introduce the new rules on environmental claims and sustainability labels, while amendments to the Civil Code incorporate the product durability guarantee regime. Both sets of amendments will enter into force on 27 September 2026.

Compliance with the new requirements will be supervised by the State Consumer Rights Protection Authority (VVTAT/SCRPA).

Latvia

Latvia has implemented the new EU consumer transparency framework through amendments to the Consumer Rights Protection Law and the Unfair Commercial Practices Prohibition Law, with corresponding changes to secondary legislation. Both sets of amendments will enter into force on 27 September 2026.

The supervisory authority is the Consumer Rights Protection Centre.

Estonia

Estonia has implemented the new EU framework through amendments to the Consumer Protection Act (CPA), adopted through the Act on Amendments to the Consumer Protection Act and the Explosives Act.

The provisions implementing the EmpCo requirements will enter into force on 27 September 2026, while the provisions concerning fines entered into force earlier, on 13 July 2026.

The new requirements will be supervised and enforced by the Consumer Protection and Technical Regulatory Authority.

How to prepare for the new requirements

Implement the EU legal guarantee notice. Display the standardised EU notice reminding consumers of their legal guarantee rights (which are at least two years). In physical shops, place the notice prominently near the point of sale; online, include a general reminder on the trader’s website.
Consider the GARAN durability label. If offering a voluntary commercial guarantee of durability covering the entire product, adopt the harmonised GARAN label in accordance with the prescribed design, content and display requirements.
Verify sustainability labels. Ensure that any sustainability label displayed on products or in advertising is based on a certification scheme established by or recognised by a public authority, with objective, publicly accessible criteria and independent compliance monitoring. Remove or substantiate any claims that cannot be supported by recognised certification or clear, specific evidence.
Review future environmental commitments. If using claims that relate to the future (e.g. “climate-neutral by 2030”), prepare a detailed, publicly available implementation plan with measurable targets and arrange for independent verification.

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