How must corporate communication change when every environmental and/or sustainability claim has to be substantiated if challenged – and a lack of evidence can lead to severe penalties? In our Q2 newsletter, we used a current project to show you that false green claims rarely arise from bad intent. In this article, we pick up the thread and show you how to make your communication EmpCo-ready now and what opportunities this opens up. The early bird … you know the rest.
A brief review
In our Q1 newsletter, we presented the regulatory basics of the EmpCo Directive (read it here). In the Q2 issue, we used a current project to show you what the new legislation specifically means for your corporate communication.
The practice test revealed something that goes beyond the individual case: false green claims rarely arise from bad intent. Rather, they arise because sustainability management, procurement, product development, sales and communication each know only part of the truth – and nobody brings the pieces together into a robust claim.
A question in search of an answer
This raises a question that goes beyond EmpCo and which we will examine more closely here: how must corporate communication change when every environmental claim has to be substantiated?
From (subjective) honesty to (objective) verifiability
Anyone applying the EmpCo requirements to existing communication for the first time almost always encounters the same pattern:
The problematic wordings are not the obviously exaggerated ones.
It is the casual statements such as “produced in a climate-friendly way”, “from responsible production” or “a step towards climate neutrality” – most of which were certainly formulated in good faith and without any manipulative intent. However – and this is the crux with EmpCo – nobody took care to back these statements up with data. It seemed obvious and self-evident.
It is precisely this self-evidence that EmpCo brings to an end. The Directive no longer requires (subjective) honesty – which was present in most cases anyway. It requires objective verifiability. And that is a qualitatively different standard:
It is not enough for a statement to be true. It must be possible to prove why it is true, who verified it and on what data basis.
From wording to process
The shift from “it’s true, isn’t it?” to “it’s proven” cannot be achieved through more careful wording. It requires a process. What is needed is
- a function that knows which evidence is required for which claim,
- documentation that can still be found two years later if challenged
- and communication that, from the outset, only promises what can be substantiated.
Without this process, any adjustment of individual wordings remains piecemeal. At best, it remedies a symptom, not the cause. The regulatory bomb is not defused. The risk remains.
Game, set and match
Companies that recognise this connection early gain an advantage that goes beyond mere regulatory compliance: those who can prove what they claim ultimately communicate more credibly – not despite, but precisely because of the stricter requirements. Words now carry more weight – and they do not get lost in a flood of identical words from competitors.
Looking ahead
When EmpCo takes effect on 27 September 2026, the theoretical requirement will become everyday practice. For companies that review their communication now, this is more of an opportunity than a burden. There is still time to calmly sort out the relationship between claim and evidence, rather than having to correct it later under time pressure.
Our offer
Together with our partner agency bcomm, we have bundled what such a process can look like in practice into a consulting package. It combines regulatory review and communication implementation from a single source, ranging from the claim check to traceable documentation of the underlying data.
We will provide you with more details in one of our next newsletters. If you would like to find out more about our offer now, please contact Louisa Kröning.
