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.
Green claims: the new rules now apply.
Directive (EU) 2024/825, “Empowering Consumers for the Green Transition” (EmpCo), enters into force.
Deadline for national transposition. Germany amended its Act Against Unfair Competition (UWG) in February 2026.
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.
Sources: Directive (EU) 2024/825; European Commission, study of environmental claims in the EU (2020)
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)).
The cost of getting it wrong.
Fines of up to
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.
Manual review does not scale.
Expert hours to review a website by hand
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.
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.
• “Eco-friendly packaging” → High risk (generic)
• “Climate-neutral delivery” → Per-se ban (offset)
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 sourceFrom domain to report in four steps.
Crawl
Every public page and document of your domain is collected, including PDFs and dynamic content.
Whole domain, not a sampleDetect
Semantic and rule-based filters isolate the passages that contain environmental or sustainability claims.
Nothing relevant left outAssess
Each claim is analysed in its context against the EmpCo risk categories and given a risk level.
Claim by claim, in contextReport
A consolidated audit report lists every finding with its rationale and a compliant alternative.
Ready to act onManual review vs generic AI vs Kairntech.
| Manual review | Generic AI assistants | Kairntech 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 |
An expert audit report, claim by claim.
“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
Concrete, verifiable results.
Sample audit of an anonymised consumer brand
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.
Built for auditors and for brands.
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
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
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.
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 auditOr 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.