Introduction
From September 27, 2026, EU rules restrict how environmental and sustainability claims can be made in consumer-facing advertising. This article explains what is changing, what you need to review before that date, and how responsibility is shared between you and Criteo.
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. The key requirement is that 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 you can specifically substantiate and explain the environmental benefit they refer to.
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. Offsetting does not reduce a product's actual emissions and can mislead consumers about its true environmental impact.
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.
Partial claims presented as whole-product claims. Presenting an environmental benefit that applies only to one aspect of a product or your 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 they are 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. Before the application date, review all of the following for claims that may fall under the Directive:
Product feeds. Titles, descriptions, and attributes in the product feeds you supply to Criteo or to retailers.
Creatives. Images, banners, video, and ad copy that contain environmental or sustainability messaging.
Landing pages. Any page consumers reach after clicking your ads.
Badges and labels. Sustainability icons, labels, or certification marks used on product listings or in creatives.
Product information and descriptions. Environmental performance claims in product detail pages and packaging inserts.
Remove or update any claim that cannot be substantiated before September 27, 2026. For claims that require substantiation, make sure you have documentation to support them and that your legal team has reviewed it.
Who Is Responsible for What
Campaigns in Criteo Commerce Max involve more than one party. Here is how responsibility is distributed.
Role | Responsibility |
|---|---|
You (advertiser or agency) | You are responsible for the accuracy and substantiation of environmental claims in the content, creatives, feeds, and product information you supply. Criteo's advertising guidelines require that all advertising complies with applicable law. Responsibility for verifying that your claims meet EmpCo requirements rests with you. |
Retailers | Retailers are responsible for environmental claims appearing on their own product pages, feeds, and advertising environments — including sustainability labels they apply to or impose on brands advertising through their platforms. |
Criteo | Criteo is not responsible for the substance or substantiation of claims in content you supply. We cannot review or guarantee the legal compliance of every claim in every asset, feed, or creative. If your campaigns use Criteo's AI-powered tools to generate or adapt ad copy, you remain responsible for reviewing all outputs before use. AI-generated content is not automatically checked against environmental claims regulations. |
A Note on AI-Generated Ad Copy
If you use Criteo AI tools to generate or adapt ad titles, descriptions, or other copy, review all outputs carefully for environmental claims before they go live. AI-generated content reflects patterns in training data and is not designed to assess regulatory compliance. You remain responsible for ensuring any claim that reaches consumers — whether you wrote it or an AI generated it — complies with the EmpCo Directive and applicable national rules.
For broader guidance on using AI-generated content responsibly, see Using Criteo AI Responsibly.
How to Get Support
Your first step for any question about how these rules apply to your business, campaigns, or markets is your own legal counsel. The specific obligations depend on the claims you use, the products and markets involved, and your advertising workflow.
If you have questions about live campaigns running in EU markets, or if your campaigns involve Criteo-generated copy and you are unsure how that affects your obligations, contact your Criteo account team. They can connect you with the right resources and escalate to the relevant teams where needed.
Do not make assumptions about compliance for a specific campaign, wording, or market without seeking legal advice.