Reliable Product Data as the Answer to EmpCo: How Manufacturers and Retailers Should Move Now

From 27 September 2026, the EmpCo Directive applies without restriction, including to content already published. For manufacturers and B2C retailers, this means one thing above all: sustainability claims must be verifiable, consistently and across every channel. Here is how clear processes in PIM and commerce make that possible without the effort spiralling out of control.

What changes on 27 September

From late September, the EU's EmpCo Directive (Empowering Consumers for the Green Transition) applies without restriction, including to content already published. There is no grace period for unsubstantiated existing claims. Environmental and sustainability statements must be evidence-backed from that date onward: on product pages, in newsletters, in catalogues, on packaging. Any company communicating "climate neutral" or "sustainable" without proof falls outside the new legal framework, regardless of size.

The penalties are not a footnote: fines of up to four percent of annual turnover or a minimum of two million euros are on the table. Consumer associations and specialised law firms are watching closely, and warning letters over unsubstantiated green claims are already common practice in other EU countries. Companies that address this now will have enough time for a clean rollout.

What compliant communication looks like

Picture a company that simply carries on as normal past 27 September. Every claim about recycled content or CO2 footprint is backed by a current, verifiable source that can be produced instantly if questioned. When a certificate expires, the claim disappears automatically from every channel until a new one is in place. Nobody scrambles to find a certification document days before a campaign launch. That is what a system built around verifiability from the outset delivers.

The real bottleneck: missing evidence

A product record can be factually accurate and still fail EmpCo compliance. "60 percent recycled aluminium" may well be true, but it carries no legal weight if nobody can confirm which certificate supports it or whether that certificate is still valid. A PIM system that manages data cleanly but does not enforce a link between claim and evidence simply moves the problem from the website into the database. The real question is how a company ensures every claim has valid, current backing without legal or compliance teams manually checking each line.

The answer starts with a compliance concept

Before touching any system, the rules need to be clear. Which types of claims require evidence? Which sources count as valid proof? Who approves a claim, and who is accountable for it? How long does a piece of evidence remain valid, and what happens automatically once it expires? No system answers these questions on its own. What's needed is a compliance concept that runs through the data model, the approval workflow and the technical build as a consistent thread. Companies that implement a new tool first and define the rules afterwards are building on sand.

Bringing it to life in PIM and commerce

Inside the PIM, evidence source and validity date become mandatory fields directly on the relevant attribute. If proof is missing or has expired, the system blocks the claim automatically before it ever reaches approval. Compliance checking sits inside the existing content workflow rather than as an extra step bolted on beforehand, which keeps the manual effort low.

On the commerce side, that same rule has to reach every storefront: online shop and printed catalogue alike. If a supplier withdraws a certificate, the affected claim disappears everywhere at once, with no manual reconciliation per channel. That reduces legal exposure and cost at the same time: less duplicated maintenance, fewer last-minute corrections.

The roadmap to the deadline

  • August 2026: Define scope, gather data, and analyse every affected channel.
  • By mid-September: Adjust channels, remove or hide unsubstantiated claims.
  • By 27 September 2026: Confirm that only verified information is visible across all channels.
  • From 27 September 2026: Launch change management to permanently align systems and processes with EmpCo.
  • After 27 September: Keep evidence current on an ongoing basis, embed approval workflows into daily operations, and design new products as EmpCo-compliant from day one.

A topic that calls for an experienced partner

Compliance requirements of this scale are rarely solved as a side project. Adjusting PIM structures and approval workflows without a clear concept risks treating symptoms rather than the underlying cause. Experience with comparable projects helps identify common pitfalls early and connect legal requirements, process design and system architecture from the start. We support manufacturers and B2C retailers in exactly this combination: from shaping the compliance framework through to technical implementation in PIM and commerce systems, delivered from one hand and with ongoing operations in mind from the outset.