"Recyclable." "Climate-neutral packaging." "Sustainably produced." Three statements that appear on millions of packages. And three statements that, after September 27, 2026, will carry serious legal risk without a watertight data foundation.
EU Directive (EU) 2024/825 — the so-called EmpCo Directive (Empowering Consumers for the Green Transition) — takes effect on that date across all 27 member states. It bans generic environmental claims that lack recognized certification or clearly verifiable evidence, and places compensation-based "climate neutrality" claims on an explicit blacklist. For packaging teams, the implication is clear: if you're still working with spreadsheets and email chains, you have a structural compliance problem — not a communications one.
The Evidence Problem: Why Spreadsheets and Email Chains Fall Short
Most companies have managed their packaging data the way it grew organically: material specifications in spreadsheets, supplier certificates as PDF attachments buried in inboxes, recyclability assessments in presentations nobody can find anymore. That worked as long as environmental claims on packaging were rarely challenged.
That is about to change fundamentally. The European Commission has made clear that there will be no grace period for existing claims and packaging after September 27, 2026. Companies should be revising their marketing, packaging, and sales materials now to meet the new evidentiary standards.
The real problem isn't a wording problem — it's a data problem. If a company can't demonstrate within a matter of days what a claim is based on — whether in response to a cease-and-desist letter or a regulatory inspection — it loses. And across a portfolio of 200, 500, or 1,000 SKUs, that simply isn't achievable with manual processes.
No transition period, no grandfathering: From September 27, 2026, all packaging, websites, and marketing materials must comply with the new requirements — including products already on the market. Those who wait risk cease-and-desist letters, injunctions, and fines.
Specifically, evidence management breaks down with traditional tools at three points:
- No version control: Which material specification was in effect at the time of printing? Which supplier certificate was valid then?
- No linkage: The claim is on the packaging, the proof is in an inbox, the certificate is with procurement — three silos, no audit trail.
- No scalability: A manual review per SKU takes hours. Across 200 items, that's weeks.
Which Data Each Claim Requires
Statements like "packaging made from 30% recycled plastic" are not prohibited — but they must be verified through supplier certificates, proof of origin, and similar documentation. Requirements vary considerably depending on the type of claim.
The EmpCo Directive prohibits four categories: generic claims such as "eco-friendly" and "sustainable" without recognized certification; compensation-based neutrality statements such as "climate neutral" based on carbon credits; partial-aspect claims presented as whole-product statements; and mandatory legal minimum requirements presented as voluntary sustainability achievements.
The third point is particularly tricky. It is prohibited to advertise a characteristic that applies to only a small part of a product in a way that implies the entire product is environmentally friendly. The claim "made from recycled material" is inadmissible if it refers only to the packaging. The correct formulation would be: "Packaging made from 100% recycled material."
On top of that, the PPWR requires manufacturers and importers to demonstrate, in a Declaration of Conformity, that each piece of packaging meets the applicable legal requirements. This declaration must be continuously updated and must contain verifiable information on material composition, substance and additive data, and recyclability assessments.
In short: any company with a green claim on its packaging needs a structured, always-accessible evidence chain — from the material specification all the way to the supplier certificate.
How a Central Packaging Data Platform Automates the Evidence Chain
Packa solves the evidence problem not by adding more manual work, but through structured data. The platform connects three layers that are siloed in traditional processes:
The result is a seamless audit chain: claim on the packaging → linked material specification → supplier declaration with certificate → recyclability assessment → LCA data. Every step is versioned, retrievable at any time, and exportable at the click of a button — for internal audits, regulatory inspections, or cease-and-desist proceedings.
EU packaging regulations create extensive documentation obligations. Recycled content shares, material compositions, and recyclability must all be verifiable. These data points are central to EPR reporting and regulatory controls. Digital preparation of this information is no longer optional — it's essential.
Real-World Example: 200+ SKUs in 2 Weeks Instead of 3 Months
A mid-sized FMCG company with 230 active packaging SKUs faces the following scenario: the sustainability team must review all packaging claims for EmpCo compliance by the deadline and produce documented evidence for every substantiated claim.
Without a central platform, the process looks like this:
- Procurement hunts down material specifications across various ERP exports and supplier emails — 3–4 weeks
- Sustainability team manually cross-references claims on packaging against available certificates — 4–6 weeks
- Missing evidence is requested from suppliers by email; response rate and turnaround time are unpredictable — 2–4 weeks
- Legal review and documentation — 2–3 weeks
Total effort: 11–17 weeks — with no guarantee that all data is complete or current.
With Packa, the same process runs differently:
- AI digitizes all existing TDS documents into structured data sets — < 1 day
- Dashboard immediately shows which SKUs are missing evidence or have outdated documentation — instantly
- Suppliers receive automated declaration requests and confirm directly within the platform — 3–5 business days
- Compliance check and export documentation — < 1 day
Total effort: approx. 2 weeks — with a complete audit chain and versioned documentation.
ROI Perspective: What a Greenwashing Violation Actually Costs
Whether an investment in structured packaging data management pays off can be answered with concrete numbers.
Cost of a greenwashing violation:
For widespread infringements with an EU dimension, fines of up to €50,000 apply. For companies with annual revenue above €1.25 million, the penalty can rise to up to 4% of annual turnover. In addition, profits generated through misleading advertising can be clawed back.
The European Environmental Bureau has documented that enforcement actions against greenwashing claims have accelerated sharply since 2022, with dozens of companies across the EU facing formal complaints and legal proceedings. With the EmpCo Directive entering into force, the surface area for such actions will grow significantly.
Beyond fines, the indirect costs are equally serious: the European Environment Agency warns that financial penalties are often not the biggest problem. A greenwashing allegation that becomes public can permanently destroy consumer trust — and that damage is neither quantifiable nor repairable.
High-profile cases illustrate the scale: In spring 2025, Frankfurt prosecutors imposed a €25 million fine on fund manager DWS for misleading ESG representations. In Italy, Shein was fined €1 million and Armani €3.5 million — for vague sustainability claims that failed to meet the required standards. ([1])
Cost of proactive data structuring:
The alternative is a one-time investment in clean data processes: structured material specifications, digital supplier declarations, automated compliance checks. This isn't a luxury — it's the baseline requirement for packaging teams to be able to use environmental claims at all.
Rule of thumb: A company with 200 SKUs carrying environmental claims and annual revenue of €50 million risks a fine of up to €2 million for a single substantiated violation — plus cease-and-desist costs, reputational damage, and printing costs for new packaging. The cost of structured packaging data management is orders of magnitude lower.
What to Do Now: The Three Most Urgent Steps
The immediate priority for companies is to inventory all environmental and climate-related claims, identify high-risk formulations, and close evidence gaps before enforcement tightens.
Capture all environmental claims on packaging, websites, product data sheets, and social media. Prioritize by risk: generic claims ("sustainable", "eco-friendly") and carbon-neutrality claims carry the highest urgency.
For each claim, check: Is a structured material specification on file? Is there a current supplier certificate? Is a recyclability assessment documented? If any of these elements is missing, the claim is not audit-proof.
Bring all packaging data onto a single central platform — with versioning, supplier connectivity, and automated compliance checks. Only then can the chain of evidence be sustainably maintained across 50, 200, or 1,000 SKUs.
Conclusion: Compliance Is Not a Communications Problem
The EmpCo Directive doesn't change what companies are allowed to say about their packaging — it changes what they have to be able to prove. The directive shifts the burden of proof onto the company. You can no longer simply claim to be green. You have to back it up with specific, verifiable data.
For packaging teams, this means: the work doesn't start when you write the copy on the pack — it starts with the data structure behind it. Companies that build that foundation now aren't just protecting their packaging claims — they're building a lasting competitive advantage, because they can communicate sustainability credibly and at scale.
Packa is the only EU-native platform that brings together material specifications, supplier declarations, recyclability assessments, and PPWR Declarations of Conformity in a single audit-proof data foundation — built from 850+ real packaging projects with 300+ enterprise customers.
