Introduction
From September 27, 2026, EU rules restrict how environmental and sustainability claims can be made in consumer-facing advertising and product information. As a retailer, you operate the advertising environment where brands promote their products — and you also make your own claims about products and sustainability on your platform. This article explains what the rules require, what to review before the application date, and how responsibility is shared between you, the brands advertising on your platform, and Criteo.
Note: This article is for general informational purposes only and is not legal advice. Consult your own legal counsel for guidance on your specific obligations, markets, and platform.
What the EmpCo Directive Is
Directive (EU) 2024/825, known as the Empowering Consumers for the Green Transition Directive (EmpCo), updates EU consumer protection rules to restrict misleading environmental and sustainability claims in advertising and product information.
The Directive does not ban environmental advertising. Specific, accurate, and properly substantiated claims remain permitted. What the rules target is vague, unverifiable, or misleading claims — commonly referred to as greenwashing. Every environmental claim must be substantiated and accurate in context.
The rules apply from September 27, 2026.
What Is Prohibited from September 27, 2026
The following practices are prohibited under the Directive:
Generic environmental claims. Terms such as "green," "eco-friendly," "sustainable," "environmentally friendly," or "climate-friendly" are prohibited unless they can be specifically substantiated and explained.
Climate neutrality claims based on carbon offsetting. Claims that a product or service is "carbon neutral," "net zero," or has a reduced or positive environmental impact are prohibited when the conclusion relies solely on carbon offsetting.
Unsubstantiated sustainability labels. Environmental labels, badges, or seals are prohibited unless they are based on a public-authority scheme or a third-party certification scheme that meets the legal standards set by the Directive. This applies to retailer-owned sustainability labels as well.
Partial claims presented as whole-product claims. Presenting an environmental benefit that applies only to one aspect of a product or business as if it applied to the whole product or business is prohibited.
Unverified future environmental commitments. Claims such as "net zero by 2030" are prohibited unless supported by a detailed, realistic, measurable, and verifiable implementation plan with regular independent verification.
What You Need to Review Before September 27, 2026
Environmental claims can appear across many surfaces on your platform. Before September 27, 2026, review all of the following:
Your product catalog and product pages. Product titles, descriptions, and attributes that include environmental claims.
Your own advertising creatives and campaigns. Any ad copy or creatives you run on your platform or externally.
Sustainability labels and badges. Labels or icons you apply to product listings on your platform — including retailer-owned sustainability programs or certifications. These must be backed by a public-authority scheme or a compliant third-party certification scheme to remain permitted.
Requirements you impose on brands. Any environmental labeling requirements or sustainability criteria you apply to brands advertising through your platform should be reviewed to ensure they remain consistent with the Directive.
Brand creatives you review and approve. When you review brand line items and creatives submitted through Criteo Commerce Yield, check that ad copy and imagery do not contain prohibited environmental claims before approving them.
Landing pages. Pages that consumers reach after clicking ads served on your platform.
Remove or update any claim that cannot be substantiated before September 27, 2026.
Who Is Responsible for What
Campaigns in Commerce Yield involve more than one party. Here is how responsibility is distributed.
Role | Responsibility |
|---|---|
You (retailer) | You are responsible for environmental claims appearing on your own product pages, catalog feeds, and platform surfaces — including sustainability labels and certification schemes you apply, and requirements you impose on brands. When you review and approve brand creatives in Commerce Yield, you also take responsibility for what you choose to allow on your platform. |
Advertisers (brands) | Brands are responsible for the accuracy and substantiation of claims in the content, creatives, feeds, and product information they supply. Criteo's advertising guidelines require that all advertising comply with applicable law. |
Criteo | Criteo is not responsible for the substance or substantiation of environmental claims in content supplied by retailers or brands. We cannot review or guarantee the legal compliance of every claim in every asset, feed, or creative. |
Your Role in Reviewing Brand Advertising
When brands submit line items and creatives for approval through the Commerce Yield review center, you have the opportunity to review content before it serves on your platform. Consider incorporating a check for prohibited environmental claims as part of your review process.
If a creative contains a claim that may be prohibited — such as an unsubstantiated "eco-friendly" badge or a carbon neutrality claim based on offsetting — you can reject it and add a comment explaining what needs to change. Brands see your comment directly in their workflow.
This is a practical step that can reduce the risk of prohibited claims appearing on your platform. For guidance on the review process, see Onsite Display Line Item Review Center.
How to Get Support
For any question about how these rules apply to your platform, product catalog, or sustainability programs, consult your own legal counsel. The specific obligations depend on the claims used, the products and markets involved, and your platform structure.
If you have questions about live campaigns, country-specific enforcement, or content running on your platform that you believe may be affected, contact your Criteo account team.
Do not make assumptions about compliance for a specific claim, label, or market without seeking legal advice.