Check your sustainability claims against the new European rules.
Get ready for EmpCo/ECGT and check sustainability claims faster and more consistently with the Green Claims Agent. Every claim comes back with an explanation, the legal grounds and a suggested rewrite. You decide.
- Less manual checking before Legal sees it
- Explanation and a suggested rewrite per claim
- Based on EU and Dutch rules and the ACM guidance
Green Claims
Product page
“Sustainable choice. Our packaging is 100% recyclable and climate neutral, so you shop with a clear conscience.”
- Sustainable choiceorange
- 100% recyclableorange
- Climate neutralred
Legal grounds · “Climate neutral”
Art. 6:193g(ae) Dutch Civil Code
Claiming a neutral, reduced or positive environmental impact based on offsetting greenhouse gas emissions.
Suggested rewrite
We reduced the emissions of this packaging by 30% compared to 2022. The remaining emissions are offset via [project].
Built with legal and sustainability expertise
Marieke Faber
Legal & compliance, Agents for Change
Gerbrich Kozijn
Legal partner
The agent gives a risk screening for human review. It is not legal advice and not a publication approval.
From 27 September 2026 the rules for sustainability claims change.
Directive (EU) 2024/825, known as EmpCo or ECGT (Empowering Consumers for the Green Transition), tightens the existing rules on misleading commercial practices. In the Netherlands it has been written into the Civil Code, with the ACM as the supervisor. In practice this is what changes:
Generic environmental claims
'Green', 'eco', 'environmentally friendly' or 'climate friendly' without further explanation are no longer allowed, unless you can demonstrate recognised excellent environmental performance.
Whole product or one aspect?
A claim about one feature, such as the packaging, may not create the impression that the whole product is sustainable.
Sustainability labels
Labels are only allowed if they are based on a certification scheme or set by a public authority. A logo of your own with no independent check is not a label.
Claims about the future
'Climate neutral by 2030' needs clear, publicly available and verifiable commitments, with a plan and independent monitoring.
Offsetting
Claiming that a product has a neutral, reduced or positive climate impact because emissions are offset is banned.
Legal requirements as a selling point
Presenting something the law requires anyway as a distinctive feature of your product is not allowed.
Do you know which claims on your website, product pages and campaigns need attention?
Book a demo→Is this on your website too?
Each of these is a sustainability claim. For every one, two questions now matter: can you show why the claim is true, and is it clear to the consumer what exactly you mean? Answering that by hand, for every product page, campaign and post, is where the time goes.
- Are we allowed to say it like this?
- Is this claim specific enough?
- Can we substantiate it well enough?
- Which information has to go with it?
- Does Legal need to look at this?
One rule set, four teams.
Marketing & communication
Keep communicating about sustainability, but concretely. Know before a campaign goes live which wording will hold up, and which needs an explanation or a source.
E-commerce
Check product pages and product copy page by page, without sending every claim past Legal. Same criteria every time, so the whole catalogue is judged consistently.
Sustainability / ESG
Make sure what the outside world reads matches your policy and the evidence you actually have. The agent shows which claim leans on which substantiation.
Legal & compliance
Stop reviewing standard claims by hand. The agent filters the routine cases and lists exactly what still needs a human judgement, so your time goes to the complex ones.
Check your sustainability claims before they go live.
Submit a page, product text, advert, document, image or video. The Green Claims Agent finds the sustainability claims in it and assesses each one against EU and Dutch law and the ACM guidance. You get more than a verdict: you get the why, the sources and a better wording.
Submit content
A URL, pasted text, a PDF or Word file, an image of a packaging, or a video.
Claims are detected
The agent picks out every sustainability claim, including labels and visuals.
Each claim is assessed
Against Directive 2024/825, the Dutch Civil Code, the ACM guidance and the advertising codes.
Risks and explanation
A colour per claim, with reasoning in plain language and the legal grounds quoted.
Suggested rewrite
Where possible, a more specific wording that keeps your message.
You decide
A list of what a human still has to check. Your reviewers correct, annotate and decide.
What you get back per claim
- Verdict
- Green, orange, red or grey, so you see the risk at a glance.
- Explanation
- Why, in plain language, without legal jargon.
- Legal grounds
- The articles involved, with the text of the provision itself.
- Sources
- Numbered references to the legislation, guidance and case law used.
- Suggested rewrite
- A concrete alternative, or the honest answer that none is possible with what the page carries.
- What to check
- The points the agent cannot settle from the page. That is where human review comes in: your own team, or a lawyer for the complex cases.
See what a check looks like.
Pick an example, run the check and read the result: which claims are fine, which need attention, why, and how you can say it instead. The claims are fictional and the result is a worked example, not a live assessment.
Submitted content
Webshop, packaging claim
“Sustainable choice. Our packaging is 100% recyclable and climate neutral, so you shop with a clear conscience.”
From vague to concrete.
A vague claim does not have to disappear. Most of the time it can be made specific, and then it is both allowed and more convincing.
Before
Our packaging is sustainable.
After
This packaging is made of 80% recycled plastic.
Substantiation needed
Supplier statement or material specification for the recycled content.
Before
Climate neutral delivery.
After
Delivered by electric van in the Amsterdam region; elsewhere by regular van.
Substantiation needed
Fleet data per region. Avoid 'neutral' if it rests on offsetting.
Before
Made with respect for nature.
After
Cotton certified by [recognised label], grown without synthetic pesticides.
Substantiation needed
Valid certificate covering this product, and the label must be a recognised scheme.
Fictional example.
Every place a claim shows up.
- Web pages and landing pages
- Product pages and product copy
- Campaigns and advertisements
- Social media posts
- Newsletters and emails
- Packaging, as an image or PDF
- Brochures and documents
- Videos and commercials
- Corporate communication
You check per page, text or file. When you submit a URL, the agent also follows the substantiation links on that page.
A verdict you can trace.
Sources with every verdict
The agent quotes the article it applies and lists the legislation, guidance and case law it used. You can check the reasoning yourself.
EU and Dutch rules, kept current
The European and Dutch rules on sustainability claims, the ACM guidance, the advertising codes and relevant Dutch case law are in the knowledge base, and are kept up to date.
Your own rules as a second lane
Add your company's own rules: banned terms, house style, which labels you accept. They are assessed next to the law, never instead of it.
Certification register
Labels found on a page are matched against a register that records whether a mark is independently checked, government-issued, or a company's own claim.
Human in control
Reviewers correct verdicts, add notes and re-run checks. The agent screens; your people decide. It is not legal advice.
Hosted in Europe
Content is stored and processed in the EU, on European infrastructure, with Mistral as the AI model: a European provider. Your content is not used to train AI models.
EmpCo, ECGT and the Green Claims Directive: what is the difference?
EmpCo / ECGT
Two abbreviations for the same law: Directive (EU) 2024/825, Empowering Consumers for the Green Transition. It amends the existing rules on unfair commercial practices and bans a number of environmental claims outright. Adopted in February 2024; the rules apply from 27 September 2026. In the Netherlands it is implemented in Book 6 of the Civil Code and enforced by the ACM.
Green Claims Directive
A separate European proposal on how explicit environmental claims should be substantiated and verified in advance. In June 2025 the European Commission announced it intended to withdraw the proposal; it is currently blocked and not in force. The Green Claims Agent does not assess against it.
ACM guidance
The Dutch supervisor's Guidelines on Sustainability Claims (Leidraad Duurzaamheidsclaims) with five rules of thumb. Not a law, but the yardstick the ACM uses when it enforces. Part of the agent's knowledge base.
'Green Claims' is used on this page as the everyday term for sustainability claims in general, not as a reference to the Green Claims Directive.
Real people, real expertise.
A team of sustainability, legal and technology specialists, working with expert partners and trusted by ambitious organisations.
Our clients
One of the most forward-thinking law firms in the Netherlands, with 250+ professionals, known for an innovative mindset and high-quality standards.
One of the fastest-growing telecom and fibre-network providers in the Netherlands, connecting thousands of households and businesses every day.
Our team
Marianne van Leeuwen
Founder
Using 20+ years in digital innovation for sustainable innovation. Most recently built the circular business at Decathlon.
Inge Demoed
New business
20+ years in digital innovation. Drove the sustainability programmes at Thuiswinkel.org.
Han Gerrits
Technology & Product
Leads product and engineering, turning sustainability workflows into dependable AI agents.
Wouter Boven
Sustainability
15+ years as a sustainability expert at companies like Coolblue, bol.com, and Odido.
Marieke Faber
Legal & Compliance
Legal expert focused on sustainability regulation.
Our partners
The Terrace
Sustainability experts
Gerbrich Kozijn
Legal experts
What is EmpCo?+
EmpCo stands for Empowering Consumers for the Green Transition: Directive (EU) 2024/825. It amends the EU rules on unfair commercial practices and adds a list of environmental claims that are always banned, such as generic claims like 'eco-friendly' without proof and climate-neutral claims based on offsetting. It also sets requirements for sustainability labels and future claims.
What is ECGT?+
ECGT is the other common abbreviation for the same directive, Empowering Consumers for the Green Transition. The ACM uses 'ECGT-richtlijn'; many others say 'EmpCo'. They are one and the same law: Directive (EU) 2024/825.
When does EmpCo apply?+
Member states had to transpose the directive by 27 March 2026, and the rules apply from 27 September 2026. In the Netherlands the implementation act was published in June 2026 (Stb. 2026, 152). Check the exact dates with your legal adviser before you rely on them.
Which sustainability claims are no longer allowed?+
Among others: generic environmental claims ('green', 'eco', 'environmentally friendly') without demonstrable recognised excellent environmental performance; claiming a product is climate neutral or has a reduced impact because emissions are offset; showing a sustainability label that is not based on a certification scheme or set by a public authority; and presenting a legal requirement as a distinctive feature of your product.
May we still say 'climate neutral'?+
Not if the claim rests on offsetting emissions. From 27 September 2026, claiming a neutral, reduced or positive climate impact for a product because of offsetting is a banned practice. Claims about actual, measured reductions remain possible, provided they are specific and substantiated.
What does the ACM say about sustainability claims?+
The ACM's Guidelines on Sustainability Claims give five rules of thumb: use correct, clear, specific and complete claims; substantiate them with facts and keep them up to date; make fair comparisons; describe future ambitions concretely and measurably; and make sure visual claims and labels help rather than confuse consumers. The ACM is the supervisor and can impose fines.
How do you check a sustainability claim?+
Ask three questions. Is it specific: does the consumer understand exactly what is claimed, and about what? Is it substantiated: is there evidence, and is it current? Is it complete: does the claim, in its context, give an accurate overall impression? The Green Claims Agent runs those questions against the applicable rules and shows you the outcome, the reasoning and a better wording.
Can AI check sustainability claims?+
Yes, as a screening step. The agent finds the claims in a piece of content, assesses each one against the legislation and guidance in its knowledge base, and explains its reasoning with sources. It does not replace a lawyer: it filters the routine cases and tells you exactly what still needs a human judgement.
What does EmpCo mean for marketing and e-commerce?+
You can keep communicating about sustainability, but generic wording has to become specific, labels have to be recognised, and every claim needs substantiation you can produce. For e-commerce this applies to every product page. Checking that by hand does not scale; that is what the agent is for.
How do I check a whole website or product catalogue?+
Page by page. Per check you submit a URL, text, a document, an image or a video, and with a URL the agent also follows the substantiation links on that page. For large numbers of product pages we look at the best approach together in a demo.
Is the agent's verdict legal advice?+
No. It is an AI-supported risk screening meant for internal human review. The final judgement always rests with a person, and for complex cases with your legal adviser.
What is the difference between EmpCo/ECGT and the Green Claims Directive?+
EmpCo/ECGT (Directive 2024/825) is in force and applies from 27 September 2026. The Green Claims Directive is a separate proposal on substantiating and pre-verifying explicit environmental claims; the Commission announced in June 2025 that it intended to withdraw it, and it is currently blocked. The agent assesses against EmpCo, the Dutch Civil Code and the ACM guidance, not against the Green Claims Directive.
Do you know which sustainability claims on your website need attention?
In a demo we run the Green Claims Agent on a page, product text or campaign of your choice, and go through the results together: which claims are fine, which need attention, and why. Thirty minutes, no preparation needed.
Prefer email? marianne@agentsforchange.nl
The Green Claims Agent screens your claims, explains why something needs attention and suggests a better wording. For most claims that is enough to move on yourself; for the complex cases you know exactly where to bring in a lawyer. It supports your own judgement and is not legal advice.