“30 percent less CO2”, “recycling-friendly”, “climate-neutral production”: claims like these can be effective in marketing, but once the EmpCo Directive takes effect on 27 September 2026, they will be subject to significantly stricter requirements. It is now more important than ever for companies to phrase product claims clearly and back them up with an appropriate, robust data foundation. But which method suits which claim? And when is a Product Carbon Footprint (PCF), a Life Cycle Assessment (LCA) or an Environmental Product Declaration (EPD) the right choice?
Note: This article is provided for general informational purposes only and does not constitute legal advice.
With the implementation of the EmpCo Directive into the German Act Against Unfair Competition (UWG), the requirements for corporate sustainability communication are increasing significantly — including at the product level. The new EU directive aims to tackle greenwashing more effectively: What matters is not only what a company communicates, but also whether its environmental claims are supported by an appropriate and transparent data foundation.
The first article in our EmpCo series, EmpCo Directive from September 2026: environmental claims under scrutiny, provides an overview of the legal requirements and crucial aspects.
For companies, three cases in particular could become critical from 27 September 2026:Companies will therefore need to be able to demonstrate precisely what an environmental claim refers to, which data underpins it and how that data was collected. At the same time, the importance of reliable product data is growing beyond EmpCo: customers, business partners and procurement bodies are increasingly demanding specific environmental metrics. Besides, a robust environmental assessment also provides valuable insights for product development, procurement and the optimisation of material and energy use.
In the second post of the EmpCo blog series, we showed how environmental claims can be systematically recorded and reviewed. At the product level, this raises the next question: which assessment method is suitable for which claim?
Not every environmental claim aimed at consumers requires a full life cycle assessment. The starting point is first and foremost what a company wants to claim and which environmental impact it concerns. Depending on the specific question, it must then be determined whether a PCF, an LCA or an EPD is the most appropriate basis.
The PCF captures a product’s greenhouse gas (GHG) emissions over a defined life cycle or across defined life cycle stages. A PCF provides a key basis for specific climate-related product claims. However, it covers only the climate impact being assessed. A low or reduced carbon footprint therefore does not necessarily mean better overall environmental performance.
For a specific, climate-related claim – for example, concerning the emissions of a particular product – a PCF can provide an appropriate basis. A general claim such as “climate-friendly”, however, is not automatically substantiated by a PCF.
A Life Cycle Assessment examines a product’s life cycle within the defined scope of the assessment and evaluates various environmental impacts. These include, among others, climate impacts, resource and water consumption, acidification, and eutrophication.
An LCA provides a more comprehensive environmental assessment and therefore a broader basis for decision-making than a carbon footprint alone. For example, it can show that a measure reduces climate impact while simultaneously increasing other environmental impacts.
The Environmental Product Declaration (EPD) provides environmental data on a product in a standardised format and is based on a life cycle assessment. It is prepared in accordance with established Product Category Rules (PCR) and includes independent verification.
EPDs are particularly common in the construction industry, but are increasingly being used in other sectors too, such as for electronics and electrical products, and, to a growing extent, in the chemical industry.
An important distinction: an EPD does not automatically constitute an environmental claim. It provides standardised environmental data. Whether and how this data can be used as the basis for a marketing claim depends on the specific communication and its context. The comparability of EPDs also requires the Product Category Rules, functional or declared unit and system boundaries to be aligned.
Even a robust PCF, a sound LCA, or an EPD does not automatically make a claim legally permissible. The assessment method and the claim must always match.
This is important for companies: the EmpCo Directive and its implementation into the UWG set requirements for the specific claim and its context. Where such claims are made, consumers must be able to understand which specific environmental aspect is being referred to and what exactly the claim relates to.
Another key aspect of product claims is the system boundary, which defines exactly what a claim relates to. Under EmpCo, an important principle is that claims must not go beyond their actual scope.
One example from the directive is a product advertised as “made with recycled material”, even though only its packaging is made from recycled material. The claim could therefore be misleading and convey a broader benefit than the underlying performance actually covers.
To substantiate credible claims, companies should therefore clearly define whether a statement relates to the entire product, individual components, the packaging or specific life cycle stages.
The same principle applies to the data foundation: a PCF for a specific product variant cannot automatically substantiate a claim about the entire product portfolio or the company. The reference object and system boundary are therefore among the most important interfaces between product assessment and sustainability communication.
can only be communicated credibly if the underlying basis for comparison is clearly defined and transparent. Otherwise, they could be considered misleading.
To ensure this, the assessment method, system boundaries, data set, reference period, and the products or product variants being compared must all be aligned. Products with the same function should be compared using consistent assessment criteria. PCF, LCA, and EPD can provide an important data foundation for this. However, the method alone does not replace the need to verify that like is indeed being compared with like.
Credible and well-substantiated product claims do not start in marketing. They begin much earlier – with data collection and sound assessments.
Our tip: First, review which environmental and sustainability claims you are already communicating or would like to communicate in future, and determine whether they can be supported by transparent, verifiable evidence. You can find guidance here.
PCF, LCA, and EPD each serve different purposes:Importantly, this data is not only relevant for external communication. It also provides valuable starting points for strategic optimisation and efficiency gains across the product life cycle.
Credible sustainability communication requires a robust data foundation. That is exactly what we help companies build — from systematically collecting and assessing relevant sustainability data to developing a sound evidence base for substantiated environmental claims and embedding the results in operational processes.
In addition, the accredited verification body offers verification of greenhouse gas inventories and transition plans in accordance with internationally recognised standards.
Would you like to put your products’ environmental claims on a robust data foundation?
Talk to our experts. Together, we’ll review what data is already available, which assessment is appropriate for your specific question and how this can provide a transparent basis for your product communication.
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