EmpCo Regulation — Kairntech (page blocks)
Regulatory compliance  |  European solution

Green claims under control.Be EmpCo-compliant.

Since 27 September 2026, vague, unproven and offset-based environmental claims are banned across the EU. Kairntech audits your entire website and documents, flags every risky claim and shows you how to fix it — before authorities, competitors or consumer groups do.

Free and with no commitmentBased on your own content
Assessment grid built on Directive (EU) 2024/825 and the UCPD Every finding traced to its source Report within 10 working days
The new EU rules

Green claims: the new rules now apply.

  1. Directive (EU) 2024/825, “Empowering Consumers for the Green Transition” (EmpCo), enters into force.

  2. Deadline for national transposition. Germany amended its Act Against Unfair Competition (UWG) in February 2026.

  3. The new rules apply in all 27 Member States.

Every consumer-facing message is in scope: websites, product pages, packaging, advertising, brochures and social media. A typical corporate website holds thousands of pages to check.

53 %of environmental claims in the EU were found vague, misleading or unfounded
40 %of claims had no supporting evidence at all
230sustainability labels in use, with very different levels of transparency

Sources: Directive (EU) 2024/825; European Commission, study of environmental claims in the EU (2020)

What EmpCo bans

Six claim types that now put you at risk.

Wording that was common on corporate websites until recently is now prohibited or presumed misleading.

Generic claims

“Eco-friendly”, “sustainable” or “green” without recognised excellent environmental performance.

Self-made labels

Sustainability labels not based on an approved certification scheme or set by public authorities.

Part sold as whole

A product advertised as green when the benefit only concerns one aspect, such as the packaging.

Offset-based neutrality

“Climate-neutral” or “CO₂-compensated” products relying on greenhouse-gas offsetting.

Legal duty as a selling point

Presenting what the law requires of all products as a distinctive feature of your offer.

Unbacked future pledges

“Net zero by 2040” without a detailed, verifiable plan and independent monitoring.

The first five are added to the EU blacklist of unfair commercial practices (UCPD Annex I) and are banned in all circumstances. Future-performance claims are misleading unless backed by clear commitments and a verifiable plan (UCPD Art. 6(2)(d)).

Risks at stake

The cost of getting it wrong.

Fines of up to

4 %

of annual turnover: the minimum maximum fine EU law requires for widespread consumer-law infringements, or €2 million where turnover is unknown.

National penalties can be higher. In France: up to 10 % of average annual turnover, or 80 % of the cost of a misleading environmental campaign.

Financial

Fines tied to turnover or campaign spend, plus the cost of reprinting packaging and re-running campaigns.

Business impact: unplanned costs and lost sales.

Legal and operational

Cease-and-desist letters from competitors and consumer groups, injunctions, forced withdrawal of products and ads.

Critical risk: products and campaigns stopped.

Reputational

Public naming by authorities, NGOs and the media erodes the trust of customers, investors and ESG raters.

Impact: trust lost for years.

Who can act against you:AuthoritiesCompetitorsConsumer groupsNGOs and media
Why it is hard

Manual review does not scale.

Expert hours to review a website by hand

1,000 pages40 h
10,000 pages400 h
≈ 50person-days of expert reading for 10,000 pages
10working days with Kairntech, report included

Assumption: an expert reads, assesses and documents about 30 pages per hour; 1 reading page = 400 words.

Claims are everywhere

Product pages, blog posts, datasheets, PDFs and sustainability reports, often in several languages.

Expertise is scarce

Each claim needs regulatory judgement in its context. Few people combine legal and marketing know-how.

Risk is widespread

In our analyses we observe a remarkably high rate of potential conflicts with EmpCo.

Our solution

Kairntech EmpCo Audit.

Powered by our Greenwashing Master Suite, Kairntech analyses entire web domains and large document collections, detects every environmental claim and assesses each one against the EmpCo criteria — then tells you what is at risk, why, and how to rewrite it.

How the audit runs, end to end

From a single domain, the pipeline crawls every public page, isolates each environmental claim and scores it against the EmpCo categories — in context, claim by claim.

[Crawl] example-brand.com — 1,284 pages collected… OK
[Detect] 312 environmental claims isolated… OK
[Assess] scoring against EmpCo categories…
 • “Eco-friendly packaging” → High risk (generic)
 • “Climate-neutral delivery” → Per-se ban (offset)
[Report] 6 breaches · 16 elevated · compiling… OK

Zero black box

Not a black-box chatbot. Every finding is explained and traced to its exact source — the quote, the URL, the page and the crawl date — so your legal and marketing teams can act on it with confidence.

Each claim comes with a plain-language rationale, its legal anchor, and a compliant rewording or deletion advice.

100% traced to source
10,000reading pages per audit (Large package)
10working days from order to report
100 %of findings traced to their source
At the core of the solution

From domain to report in four steps.

01

Crawl

Every public page and document of your domain is collected, including PDFs and dynamic content.

Whole domain, not a sample
02

Detect

Semantic and rule-based filters isolate the passages that contain environmental or sustainability claims.

Nothing relevant left out
03

Assess

Each claim is analysed in its context against the EmpCo risk categories and given a risk level.

Claim by claim, in context
04

Report

A consolidated audit report lists every finding with its rationale and a compliant alternative.

Ready to act on
Transparent, step-by-step pipelineEvery decision logged and traceableReproducible, recomputable results
Comparative analysis

Manual review vs generic AI vs Kairntech.

Manual reviewGeneric AI assistantsKairntech EmpCo
Coverage
A sample of pages
One page or file at a time
Entire domain and document sets
Time to result
Weeks of expert reading
Fast, but copy-paste page by page
Report within 10 working days
Consistency
Depends on the reviewer
Varies from one run to the next
One grid, reproducible results
Traceability
Notes and spreadsheets
Opaque reasoning, hard to audit
Every finding linked to its source
Deliverable
Comments to consolidate
A chat answer
Expert audit report with rewording
Your audit report

An expert audit report, claim by claim.

Finding #127example-brand.com/products/… | EN | crawled 02/10/2026
ClassificationBreach
SeveritySerious
Claim typeGeneric
Per-se banYes
“Our packaging is 100 % eco-friendly.”
Rationale
Generic environmental claim; no recognised excellent environmental performance is shown in context.
Missing context
Which material, which environmental benefit, and on what evidence.
Legal anchor
UCPD Annex I, No. 4a, as added by Directive (EU) 2024/825
Suggested rewording
“Our cardboard packaging is made from 80 % recycled fibre.”
  • Management summary with risk overview and action priorities
  • Classification, severity and per-se ban for every claim
  • Plain-language rationale and legal anchor
  • Missing context and evidence clearly stated
  • Compliant rewording or deletion advice
  • Source quote, URL, page and crawl date
  • Delivered as interactive HTML and PDF
First results

Concrete, verifiable results.

Sample audit of an anonymised consumer brand

73 %of analysed claims flagged as high or elevated risk
6claims falling under a per-se ban
30 / 30claims fully analysed
10working days to deliver
We offset our CO₂.Breach: climate neutrality · Per-se ban: yes

No volume, method, timeframe or verification; neutrality based on offsetting is banned.

Bamboo produces 35 % more oxygen than a comparable tree.Breach: unsubstantiated figure

No evidence, baseline or measurement method anywhere in the source.

Use cases

Built for auditors and for brands.

Audit, certification & consulting firms

Add an AI-powered EmpCo service to your portfolio

  • Screen thousands of client pages in days
  • Keep your experts on validation and advisory
  • Serve many more clients without extra headcount
  • Hosted by Kairntech or deployed in your infrastructure
Companies selling to EU consumers

Clean up your green claims before anyone else spots them

  • Marketing: check content before it goes live
  • Legal & compliance: document your due diligence
  • CSR: align claims with your evidence
  • Agencies: offer EmpCo checks to your clients
Why Kairntech

Our key differentiators.

Transparent by design

Not a black-box chatbot: the analysis is broken down into documented, controlled steps.

Audit-proof logging

Every intermediate result is recorded, so findings can be justified and recomputed.

Regulatory expertise

Assessment grid built on EmpCo and the Unfair Commercial Practices Directive.

Built for scale

Thousands of pages and thousands of claims per domain, at a fixed price.

EU AI Act ready

Deterministic orchestration and traceability support AI governance requirements.

European and flexible

Use our hosted service or run the solution inside a partner’s infrastructure.

Take it to the next level

Ready to make your claims EmpCo-proof?

Send us your domain and we run a free flash audit — a sample EmpCo report on a selection of real findings from your own content, with no obligation.

Book my free flash audit
Free and with no commitmentAnalysis of your own website or documentsDirect exchange with an EmpCo expert

Or write to us: info@kairntech.com

Frequently Asked Questions

Directive (EU) 2024/825, “Empowering Consumers for the Green Transition”, amends the Unfair Commercial Practices Directive and the Consumer Rights Directive to protect consumers against misleading environmental claims. It applies in all EU Member States from 27 September 2026.

Every company that makes environmental or sustainability claims to consumers in the EU, whatever its size or sector: on its website, product pages, packaging, advertising, brochures or social media.

Every environmental or sustainability claim found on the agreed domain, assessed against the EmpCo risk categories: generic claims, sustainability labels, offset-based neutrality, claims about the whole product, legal requirements presented as advantages and future pledges.

No. It is an automated risk screening that prioritises what your legal team or counsel should review. On request, our experts can help validate findings and rework your communication.

All publicly accessible pages and documents of the agreed domain and subdomains, without login. Content behind authentication is not accessed.

Yes. Document collections such as brochures, product sheets or sustainability reports can be analysed as well. Ask us for a custom scope.

Multilingual websites are supported, and further languages can be added without redesigning the analysis.

Yes. We offer partner and white-label models, with the solution hosted by Kairntech or deployed in your own infrastructure.