Regulation · EU · 2026

EmpCo and PPWR — green claims and packaging rules hitting construction products in 2026

Two EU regulations reach their application dates within weeks of each other. From 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR) sets binding requirements for all packaging placed on the EU market. From 27 September 2026, the EmpCo Directive bans unsubstantiated environmental claims in consumer-facing marketing. Both affect construction product manufacturers directly.

Part 1 — EmpCo: the end of vague green marketing

The Empowering Consumers for the Green Transition Directive (EU) 2024/825 — EmpCo — amends the EU Unfair Commercial Practices Directive. It entered into force in March 2024, member states had to transpose it by 27 March 2026, and the rules apply to companies from 27 September 2026.

Many companies assumed the pressure was off when the standalone Green Claims Directive proposal was withdrawn in June 2025. It was not. EmpCo was already law by then, and it carries the enforcement weight: penalties can reach up to 4% of annual turnover in the relevant member state, depending on national implementation.

What gets banned

Practice	Status from 27 Sep 2026	Example
Generic environmental claims without proof	✗ Banned	"Eco-friendly insulation", "green concrete", "environmentally friendly windows" — unless recognised excellent environmental performance can be demonstrated
Offset-based climate neutrality claims	✗ Banned	"Climate-neutral doors" based on purchasing carbon offsets — banned entirely, regardless of offset quality
Self-created sustainability labels	✗ Banned	An in-house "green product" badge not backed by a certification scheme or public authority
Future claims without a verified plan	✗ Banned	"Net zero by 2030" without clear commitments, an implementation plan, and external verification
Specific, substantiated claims	✓ Allowed	"Frame contains 68% recycled aluminium, verified per EN 15343" — one clearly named aspect, backed by evidence

ℹ The European Commission has published a FAQ (first edition November 2025, updated May 2026) with concrete examples of allowed and banned wording. It is not legally binding, but courts and authorities are expected to use it when interpreting the directive.

Why this matters for construction products

Construction marketing is full of exactly the language EmpCo targets: "sustainable timber", "eco insulation", "green steel", "climate-friendly cladding". From September 2026, any such claim made to consumers needs to be either dropped or substantiated with verifiable evidence.

This is where life cycle data stops being a nice-to-have. The practical substantiation chain for an environmental claim about a construction product runs through quantified evidence: a verified EPD, a product carbon footprint, recycled content certification, or equivalent documentation. Companies that already know their numbers can rewrite claims to be specific and compliant. Companies that don't will have to go quiet about sustainability at exactly the moment buyers are asking about it.

⚠ Honest scope note: FastLCA gives you indicative embodied carbon estimates — useful for understanding your numbers, screening products, and preparing for an EPD. It is not claim substantiation. For B2C marketing claims under EmpCo, you need verified evidence such as a third-party verified EPD or certified recycled content. Think of early-stage LCA as step one of the substantiation journey, not the destination.

Part 2 — PPWR: packaging rules with teeth

The Packaging and Packaging Waste Regulation (EU) 2025/40 replaces the 1994 Packaging Directive. As a regulation, it applies directly in every member state without national transposition. It entered into force on 11 February 2025 and applies from 12 August 2026, with further requirements phasing in through 2030 and beyond.

It covers all packaging placed on the EU market, regardless of material or origin — including the industrial and transport packaging that construction products ship in: pallet wrap, strapping, protective film, cartons, timber crating.

Timeline

✓

11 Feb 2025

PPWR entered into force

18-month transition period for compliance preparation.

→

12 August 2026

General application date

Substances of concern limits (PFAS, heavy metals), packaging minimisation, conformity assessment, EU declaration of conformity and technical documentation, EPR registration. Empty space in grouped/transport/e-commerce packaging capped at 40%.

○

2028–2029

Harmonised labelling rolls out

Material composition labels per implementing acts, phased in after adoption.

○

1 January 2030

Design-for-recycling grades + recycled content targets

All packaging must meet recyclability performance grades. Minimum recycled content targets for plastic packaging begin. Reuse targets for transport packaging apply.

○

2040

Higher reuse and recycled content targets

Second-stage targets increase across packaging categories.

What construction manufacturers should check first

Three practical exposure points for a typical building products manufacturer:

1. Transport packaging reuse targets. PPWR sets reuse targets for transport packaging used between economic operators. If your products move on single-use packaging between factory, distributor and site, the 2030 targets will require systemic change — reusable pallets, crates, and wrapping systems with return logistics.

2. Conformity documentation from August 2026. Packaging needs a conformity assessment, an EU declaration of conformity and technical documentation before being placed on the market. If nobody in your organisation owns "packaging compliance" today, someone needs to by August.

3. The 40% empty space rule. Grouped, transport and e-commerce packaging may not exceed a 40% empty space ratio unless technically unavoidable. Oversized protective packaging for fittings, hardware and components is squarely in scope.

Know your product's numbers first

Whether it's EmpCo claim substantiation or packaging decisions under PPWR, everything starts with understanding where your product's environmental impact actually sits. FastLCA gives you a free, transparent embodied carbon estimate in minutes.

Open LCA calculator → CBAM guide →

Frequently asked questions

Does EmpCo apply to B2B marketing of construction products?

EmpCo amends consumer protection law, so its prohibitions target business-to-consumer communications. However, construction product marketing frequently reaches consumers — websites, brochures, and retail channels are consumer-facing even when your primary customers are trade. Many member states also apply unfair competition rules between businesses, and competitors can bring claims. Treating B2B channels as exempt is risky in practice.

Can I still say my product is "carbon neutral" if I buy high-quality offsets?

No. From 27 September 2026, claims that a product has a neutral, reduced or positive climate impact based on offsetting are banned outright, regardless of offset quality. Specific claims about actual emission reductions in your own operations or supply chain remain possible if substantiated.

Is an EPD enough to substantiate a green claim under EmpCo?

An EPD is strong evidence for specific, quantified claims about the aspects it covers — for example declared GWP values. But an EPD alone does not make a product "green" or "sustainable"; those generic claims remain problematic regardless of documentation. The compliant pattern is a specific claim tied to specific verified data, such as declared embodied carbon per unit or certified recycled content.

Does PPWR apply to packaging used only between businesses?

Yes. PPWR covers all packaging regardless of origin — sales, grouped and transport packaging, industrial and commercial as well as household. Transport packaging between economic operators is specifically subject to reuse targets from 2030.

Will the PPWR application date be postponed?

Some member states have pushed for postponement to January 2027, and the Commission's Environmental Omnibus proposes simplifications to reporting requirements. As of mid-2026, no postponement has been adopted, and businesses are being advised to prepare for the 12 August 2026 date. Check current status with official EU sources before making compliance decisions.

Where can I find the official texts?

EmpCo is Directive (EU) 2024/825, and PPWR is Regulation (EU) 2025/40 — both available on EUR-Lex. The Commission's EmpCo FAQ and PPWR guidance documents provide practical interpretation. For compliance decisions, consult a qualified legal professional — this page is informational only.