The EU is stepping up its fight against greenwashing. The focus is on the Empowering Consumers for the Green Transition Directive (EU) 2024/825 ("EmpCo"); meanwhile, the proposed Green Claims Directive has been suspended for an indefinite time.

The EmpCo introduces stringent restrictions for B2C green marketing with the aim to combat greenwashing and make green claims reliable, comparable, and verifiable, thereby empowering consumers to make informed, sustainable choices. The new provisions must be transposed into national laws by all EU Member States by 27 March 2026, and will apply from 27 September 2026 EU-wide.

Sustainability labels (i.e., trust, or quality marks highlighting environmental or social aspects), must be based on a third-party certification scheme or issued by a public authority. Self-certification with internally developed sustainability labels is prohibited. Any certification scheme relied upon must operate transparently, apply non-discriminatory criteria, provide for independent monitoring, and include clear procedures for addressing non-compliance.

Generic environmental claims such as "environmentally friendly" or "green" must be clearly and prominently specified on the same medium (e.g., on the product packaging) or recognized excellent environmental performance must be demonstrated (e.g., via the EU Ecolabel). In practice, limited space on packaging will require particularly careful wording and scoping of such claims. Brand names, trademarks, or logos suggesting environmental benefits may also trigger substantiation requirements.

Forward-looking environmental claims such as "net-zero by 2030/2050" must be supported by a detailed, realistic implementation plan with measurable and time-bound targets regularly verified by an independent third-party. These commitments must be made publicly accessible (e.g., via QR codes).

Climate claims such as "climate neutral" must not be based on CO2 compensation schemes. The EmpCo also prohibits presenting a feature as "distinctive" for a product if that feature simply meets a legal requirement applicable to all products within the relevant category.

In addition, the EmpCo further introduces harmonized information requirements for statutory warranty rights ("guarantee of conformity") and for voluntary commercial durability guarantees offered by producers. Commission Implementing Regulation (EU) 2025/1960 specifies the mandatory design and content of the information to be provided to consumers before they are bound by a contract (e.g., at the point of sale). Any voluntary durability commitments offered by life sciences companies, such as extended functional guarantees for medical devices, must be communicated using the harmonized format.

The new requirements have direct implications for all life sciences companies promoting environmental or social benefits like recyclability, climate neutrality, energy efficiency, or ethical sourcing – whether in relation to products, packaging, or corporate branding. Such claims should be carefully reviewed, precisely scoped, and supported by robust documentation. Non-compliance may trigger enforcement actions by authorities, competitors, or patient watchdog organizations, expose companies to injunctions and sanctions under national law, and entail significant reputational risk.