Guide · Directive (EU) 2024/825

The EmpCo directive for Shopify merchants: what changes on 27 September 2026

Updated 10 August 2026 · 7-minute read

The Empowering Consumers for the Green Transition directive — Directive (EU) 2024/825, usually shortened to “EmpCo” — is the biggest change to EU marketing law in a decade. From 27 September 2026 it bans a list of green-marketing practices outright and requires new information on every product page selling physical goods. If your store sells to consumers in the EU, it applies to you.

Who is in scope

The directive amends the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD), which apply to any trader dealing with EU consumers. Three points matter for store owners:

• Location doesn’t exempt you. A US or UK store shipping to EU consumers is in scope, exactly like an EU-based one.
• Size doesn’t exempt you. There is no small-business carve-out.
• It’s B2C. Pure B2B sellers are outside the UCPD; mixed stores are in scope for their consumer sales.

The timeline

• 26 March 2024 — the directive entered into force.
• 27 March 2026 — deadline for member states to adopt national implementing law.
• 27 September 2026 — the national rules apply. This is the date that matters for your product pages.

Transposition is uneven — a number of member states were still finalising national law through 2026 — but the application date is set by the directive itself, and enforcement ramps up from there.

Part one: claims that become banned

The directive adds new entries to the UCPD’s Annex I — the “blacklist” of practices that are unfair in all circumstances, with no case-by-case balancing. These are the ones most likely to be sitting in your product copy today:

Three severity levels, and the difference matters:

• Banned — prohibited outright. “Carbon neutral” based on offsets cannot be fixed with better evidence; the claim itself is on the blacklist. Full guide →
• Fix or substantiate — banned unless a condition is met. Generic claims survive only with a recognised certification that covers the claim, or specifics stated clearly on the same page. Full guide →
• Review — depends on facts a scanner can’t know: whether your durability figure is evidenced, whether a legal requirement really covers all competing products. These need a human decision, and honest tooling says so rather than calling them violations.

Part two: information you must add

The second half of the directive works in the other direction — things that must now appear on product pages:

The harmonised legal-guarantee notice

Every seller of goods must inform consumers about the EU’s two-year legal guarantee of conformity using a harmonised notice with a fixed design, set by Implementing Regulation (EU) 2025/1960. The design may not be re-typeset or restyled — the regulation specifies the artwork, and online use must be in colour. This applies whether or not you make a single green claim.

The durability-guarantee label

If a producer offers a free commercial guarantee of durability covering the whole product for more than two years, the harmonised durability label (same regulation) must be shown — directly before the order is placed. If that doesn’t describe your products, this label doesn’t apply to you; showing it wrongly would itself be misleading.

Software-update information

For goods with digital elements, sellers must present the minimum period during which the producer provides software updates (CRD Art 6(1), as amended). If the producer states a period, it belongs on the product page.

Enforcement: who comes knocking

UCPD enforcement is national — consumer-protection authorities in each member state. Two things make this directive sharper than most:

• For widespread cross-border infringements, the CPC framework requires fines with a maximum of at least 4% of the trader’s annual turnover in the member states concerned.
• In Germany, competitors and consumer associations can enforce unfair-practice rules directly through civil claims (UWG) — a cease-and-desist letter from a competitor’s lawyer is a realistic first contact, and German courts have already ruled restrictively on “climate neutral” advertising (BGH, klimaneutral, 2024). Germany has transposed the directive into the UWG (Third UWG Amendment Act, BGBl. 2026 I Nr. 43, in force 27 September 2026); Gransko findings cite the German provision alongside the EU one.

What to do before the deadline

1. Inventory your claims. Scan products, collections, pages and blog posts — green claims accumulate everywhere, not just descriptions.
2. Remove or replace banned claims — offset-based climate claims first; they have no substantiation path.
3. Decide each generic claim: certification that covers it, same-page specifics, or a rewrite to something verifiable.
4. Check your badges. Any sustainability label you didn’t get from a third-party-verified scheme should go.
5. Add the guarantee notice to product pages — mandatory for all goods sellers.
6. Keep watching. New products and edits reintroduce claims; make rescanning automatic.