EU’s New Anti-Greenwashing Rules Take Effect: What Vietnamese Businesses Need to Know

Greenwashing refers to creating false or misleading impressions about the environmental benefits of a product, service or business. Directive (EU) 2024/825 on empowering consumers for the green transition, commonly known as EmpCo (short for Empowering Consumers), introduces additional rules to prevent greenwashing while improving information on product durability and reparability. [1]

Key changes

Generic environmental claims must meet strict conditions. When used as generic environmental claims, expressions such as “green” or “environmentally friendly” are prohibited unless the business can demonstrate recognised excellent environmental performance relevant to the claim. This may be established through the EU Ecolabel, EN ISO 14024 Type I ecolabelling schemes officially recognised in Member States, or top environmental performance under other relevant EU legislation. A few isolated positive results are not sufficient to justify broad claims. [2]

Benefits relating to one part must not be presented as benefits of the whole. Claims about an entire product or business must not be based solely on a single feature or activity. For example, if only the packaging contains recycled material, the message must not lead consumers to believe that the product inside is also made from recycled material. [2]

Sustainability labels must meet the conditions for their use. Sustainability labels may only be displayed if they are based on a certification scheme meeting the Directive’s requirements or are established by EU public authorities. Businesses therefore need to check the basis on which labels are awarded and the conditions for their use, including any self-designed “green” logos. [3]

Carbon offsetting must not be used to claim climate benefits for a product. Businesses must not rely on greenhouse gas offsetting outside a product’s value chain to claim that the product is carbon neutral or has a reduced or positive climate impact. Businesses may still communicate their investments in environmental projects, but the information must be transparent and must not mislead consumers about the product’s actual impact. [3]

Future environmental commitments must be supported by an implementation plan. Claims about future targets, such as achieving net-zero emissions, need to be supported by clear, publicly available and verifiable commitments. The implementation plan must be detailed and realistic, with measurable targets, deadlines and allocated resources. Progress must be regularly verified by an independent third-party expert, whose findings must be made available to consumers. [3]

The new rules also prohibit false information about durability, presenting goods as repairable when they are not, or encouraging the replacement of consumables earlier than technically necessary. Additional pre-purchase information requirements cover legal guarantees, commercial guarantees of durability, reparability and software updates, as applicable. [2]

Distinguishing applicable rules from a proposal that has not been adopted

The new EmpCo rules have applied since 27 September 2026. The Directive entered into force on 26 March 2024, and EU Member States were required to transpose its provisions into national law by 27 March 2026. The date on which the Directive entered into force must be distinguished from the date on which the new rules began to apply. [1] [3]

Meanwhile, the Green Claims Directive is a separate proposal on the substantiation and communication of environmental claims, which the European Commission still lists as pending. Its proposed requirements therefore cannot be treated as legal obligations already in force. [4]

According to European Commission guidance, enforcement is the responsibility of national competent authorities and courts. Businesses need to check the rules and guidance in each market where they operate, including how to address non-compliant information on existing stock. [3]

Implications for Vietnamese businesses

EmpCo regulates business-to-consumer (B2C) commercial practices involving both goods and services. Vietnamese businesses marketing and selling to EU consumers need to review environmental claims on packaging, websites, e-commerce platforms and in advertising. Being based outside the EU does not automatically exclude a business from the relevant requirements. [3]

For manufacturers, contract manufacturers and raw material suppliers in Vietnam, evidence requirements may arise through customers and supply chain contracts. For example, EU buyers may request data on materials and emissions, calculation methodologies and traceability records to substantiate their claims. This is an important indirect impact; it does not mean that all business-to-business (B2B) transactions fall directly within the scope of EmpCo.

Businesses can prioritise four actions:

1. Review existing messages: Create an inventory of environmental claims and check content published by agents and distributors. Prioritise correcting non-compliant information on online channels.

2. Prepare supporting evidence: For each claim, clearly identify its subject, scope, reporting period, methodology, basis for comparison and responsible person. Distinguish information about the packaging from information about the product inside.

3. Check labels and the scope of certification: Verify the certification scheme’s conditions, the right to use labels or certification marks, and the validity of certification. Do not extend assessment findings beyond the scope that has been confirmed.

4. Coordinate with EU partners: Agree on responsibilities for providing evidence, approving content and addressing non-compliant information on goods already distributed. Existing stock is not automatically exempt; corrective measures should align with guidance and enforcement practices in each market. [3]

Managing reliable data and accurately communicating the scope of results achieved will help Vietnamese businesses strengthen customer trust. Coordination between technical, procurement, legal and marketing teams is essential to ensure that environmental messages are consistent with the underlying evidence.