From 2026, EU packaging regulations will require environmental claims to be scientifically verified, affecting brand messaging, supplier verification, and digital traceability across supply chains. Directive (EU) 2024/825-also known as Empowering Consumers for the Green Transition (EmpCo)-mandates that claims such as "climate neutral," "recyclable," or "biodegradable" be validated by independent third-party certification before appearing on EU packaging. Member states must transpose EmpCo into national law by March 2026, ahead of its full application on September 27, 20261Changes to sustainability communication – EmpCo applies from 2026 - FLUSTIX.
Background
The policy aims to combat greenwashing by grounding sustainability claims in verifiable evidence. Previous court rulings, including Germany's Federal Court of Justice in 2023, have already indicated the need for scientific substantiation2Top Ten 2025: Digital packaging becomes mandatory: EU regulation against greenwashing - packaging journal. The broader Packaging and Packaging Waste Regulation (PPWR), effective August 12, 2026, further supports digital transparency, mandating harmonised labelling and digital product passports for material composition and environmental attributes3Packaging compliance goes digital in 2026: evidence trails, QR codes and the end of vague “green” claims - Packaging Post.
Details
Under EmpCo, vague or general environmental claims must be supported by objective evidence and may only be used if verified by third-party certification schemes. Claims without transparency or scientific documentation will face restrictions or legal action1Changes to sustainability communication – EmpCo applies from 2026 - FLUSTIX. Companies using self-created seals must transition to recognised schemes that meet requirements for open access, transparent standards, and independent assessment1Changes to sustainability communication – EmpCo applies from 2026 - FLUSTIX.
PPWR introduces digital compliance measures, including QR-coded digital product passports for packaging. Brands must integrate packaging data-such as material layers, recyclability, supplier certificates, lifecycle assessments, and chain-of-custody documentation-using visible or scannable labels that align with digital standards3Packaging compliance goes digital in 2026: evidence trails, QR codes and the end of vague “green” claims - Packaging Post. Non-compliance may result in recalls, fines, or market withdrawal4PPWR Compliance Guide 2026: EU Packaging Requirements & Deadlines.
Third-party verifiers, including UL Solutions, provide Environmental Claim Validation (ECV), product carbon footprint (PCF) verification, lifecycle assessments (LCA), and Environmental Product Declarations (EPD), supporting independent substantiation for packaging claims5Credibility in Product and Packaging | UL Solutions. SGS Green Marks certify attributes such as recycled content, compostability, or biobased materials, often linking certification to QR codes to enhance traceability6Can You Trust ‘Green’ Product Claims?.
Outlook
As enforcement dates approach, packaging and sustainability teams must synchronize artwork, regulatory compliance, and digital infrastructure. Companies are required to collect evidence trails-including certifications, LCA reports, supplier declarations, and digital identifiers-and integrate them into SKU-level packaging data archives. Prepared organizations will be better positioned to avoid legal risks and maintain market access in a changing compliance environment.
