Checking EmpCo readiness: 4 questions to Theresa Glammert-Kuhr

Theresa, EmpCo is becoming an important topic for organisations making sustainability claims. Can you briefly explain what it is and why it matters?

TGK: The EU Directive on Empowering Consumers for the Green Transition is designed to tackle greenwashing and give consumers greater confidence in environmental claims and sustainability labels. From 27 September 2026, organisations making environmental claims are expected to back them up with verifiable evidence, and sustainability labels may only be used if they are supported by independent certification schemes or certification systems recognised by public authorities. This is important because organisations are expected to no longer rely on broad or poorly substantiated environmental claims. Instead, they are expected to demonstrate the credibility of their claims through evidence, helping to build trust with consumers while reducing regulatory and reputational risks.

What challenges are organisations facing as they prepare for these new expectations?

TGK: For organisations that operate sustainability labels, standards, certification schemes, or programmes, the challenge is often not creating new requirements, but demonstrating that their existing framework can consistently support credible claims. Many schemes have evolved over time, with requirements, assurance processes, governance structures, and guidance spread across different documents and systems. As EmpCo raises expectations around transparency and credibility, scheme owners are expected to be able to clearly show how their label is governed, how compliance is assessed, how decisions are made, and how the scheme supports the use of sustainability labels and related communications in practice.

Many organisations are wondering where to start. What would be the first step?

TGK: A good first step would be to inventory every consumer-facing sustainability label and environmental claim and map it to the scheme requirements, evidence, and assurance processes that support it. This helps organisations understand how their claims are supported and where documentation, controls, or governance arrangements may need strengthening. From there, scheme owners and programme operators should take a step back and review their framework as a whole. This includes assessing whether the scheme requirements, assurance processes, governance structures, and supporting documentation are clear, transparent, and auditable, and whether roles and responsibilities are clearly defined. Given that EmpCo is expected to require sustainability labels to be supported by independent certification or verification schemes, organisations should also evaluate whether their assurance model includes a robust verification process carried out by an independent certification body accredited to internationally recognised standards such as ISO 17065.

How does FLOCERT’s Readiness Assessment help organisations understand where they stand?

TGK: FLOCERT's EmpCo Readiness Assessment is specifically designed for organisations operating sustainability labels, standards, certification schemes, codes, or programmes. Unlike generic checklists or self-assessments, it provides an in-depth review that combines AI-supported analysis with independent expert evaluation. FLOCERT sustainability scheme experts review the framework from a technical and assurance perspective, assessing whether the scheme is designed in a way that is clear, verifiable, auditable, and supported by appropriate governance, oversight mechanisms, and documentation. The outcome is a practical readiness report that provides organisations with a high-level, non-exhaustive overview of their current position. It highlights strengths, identifies opportunities to enhance transparency and controls, and offers recommendations for improvement. Importantly, it is a preparatory assessment that helps organisations understand their readiness and identify improvement opportunities; it is not a legal conformity assessment or future accredited claim verification.