EmpCo on the horizon: How sports organisations can stay ahead of the game and not fall foul of the new EU rules on greenwashing

As the largest ever FIFA Men's World Cup kicks off across the United States, Canada and Mexico this summer, the eyes of the world will be on football. Such scale and scrutiny also bring increased focus on environmental and social considerations. 

Scientists project the tournament will generate around 9 million tonnes of CO₂e (air travel comprising approximately 7.7 million), which the US EPA equates to running around two million petrol-powered cars for a year. Extreme heat is also a key consideration, particularly for player welfare and event management, with research suggesting most host cities are likely to experience elevated temperatures during the tournament.

FIFA has acknowledged these challenges and taken steps to address them, including adopting a 2026 World Cup specific sustainability and human rights strategy, scheduling matches in hotter cities during evening hours, introducing mandatory three-minute hydration breaks in each half, deploying cooling infrastructure for fans and players, and implementing enhanced medical readiness measures that scale according to real-time conditions.

Beyond the tournament, individual clubs are also demonstrating how sustainability strategies can be embedded at an organisational level. Liverpool FC's "The Red Way" strategy has won various sustainability awards on the basis of its level of ambition (it is aligned with the UN Sustainable Development Goals and the UN Sports for Climate Action Framework, the latter of which requires signatories to target net-zero by 2040) and for the way it has been promoted (by the end of the 2024-2025 season, approximately 45% of Liverpool’s fans were aware of The Red Way, up from just 14% at the end of the 2022-2023 season). The club’s latest progress report references tangible commercial benefits of its strategy, including strengthened partnerships with sustainability-aligned business partners and significant waste avoidance and material efficiencies. Earlier this year, the club reported a reduction in carbon emissions through measures including increased renewable electricity procurement and investment in sustainable aviation fuels. 

At the national level, UK Sport also announced earlier this year a refreshed environmental strategy that targets net-positive environmental impact by 2040, highlighting financial drivers such as cost savings from waste elimination, extending the lifespan of kit, merchandise and event infrastructure, and safeguarding the long-term viability of sport itself.  

As sports organisations navigate soaring temperatures, growing stakeholder expectations and demands for more matches and spectacle, a well-crafted sustainability strategy –  underpinned by strong governance and clear internal accountability – can both demonstrate responsible leadership and drive financial value through cost savings, stronger commercial partnerships and long-term financial resilience.

The regulatory environment is keeping pace. The European Union is introducing new legislation designed to ensure that environmental commitments are credible and consumer-friendly and raise the bar for how sustainability claims are communicated. 

In this blog post, we explore what this new legislation – the EU Directive on Empowering Consumers for the Green Transition (also known as the “EmpCo” or “ECGT” Directive) – will mean for sports organisations and how they can get ahead of the game before the requirements begin to apply.

Enter the EU’s Directive on Empowering Consumers for the Green Transition

EmpCo will start applying from 27 September 2026. It aims to tackle unfair sustainability-related commercial practices in the EU that mislead consumers, such as greenwashing, by amending the existing Unfair Commercial Practices Directive (“UCPD”). 

One of its main functions is to restrict the use of certain environmental claims unless they are properly substantiated. “Environmental claims” means any message or representation which is not mandatory under EU or national law, in any form, in the context of a commercial communication, which states or implies that a product, product category, brand or trader has a positive or zero impact on the environment, is less damaging to the environment than other products, product categories, brands or traders, or has improved its impact over time. It also imposes increased controls on the use of sustainability labels and the making of GHG emission-related claims based on offsetting. 

Importantly, the new rules apply to organisations across all sectors, meaning they extend to sports organisations, sponsors, licensees and broadcasters making environmental claims in a commercial context.

Whilst EmpCo is principally a business-to-consumer (“B2C”) instrument, Member States are free to extend equivalent protection to business-to-business (“B2B”) relations at national level (and some have already done so in respect of the underlying UCPD).

So how will EmpCo reshape the playing field for sports organisations? 

Here are the key changes to be aware of:

• Carbon offset-based neutrality claims on products are banned. It will be prohibited to claim that a product has a neutral, reduced or positive impact on the environment if the claim is based on offsetting of greenhouse gas emissions outside the value chain. This ban covers claims such as "climate neutral", "CO₂ neutral certified", "carbon positive", "climate net zero" and "climate compensated". 

  For example, a sports kit manufacturer will not be able to market a jersey as "carbon neutral" on the basis that it has purchased carbon credits to offset the emissions generated during production and shipping. Instead, any such claim would need to reflect genuine reductions in the product's actual lifecycle emissions. 

  Importantly, this specific prohibition applies to product-level claims. Claims based on offsetting at company level (for example, a club claiming to be "carbon neutral" as an organisation) are not caught by this particular ban (but remain subject to other provisions of EmpCo and wider considerations that mean such claims should still be clearly communicated and substantiated). Organisations may also continue to communicate about their investments in environmental initiatives, including carbon credit projects, provided such information is presented transparently and is not misleading.

• Generic environmental claims require substantiation. EmpCo bans the use of generic environmental claims unless they are properly substantiated by demonstrating recognised excellent environmental performance. This includes commonly used claims such as "environmentally friendly", "eco-friendly", "green", "ecological", "climate friendly" and "carbon friendly". 

  For example, a football club that describes its matchday operations as "eco-friendly" in promotional materials would need to substantiate that claim with evidence of recognised excellent environmental performance. A general reference to recycling initiatives or reduced single-use plastics, without independent verification or measurable benchmarks, would not be sufficient. 

  A generic claim may be avoided altogether if the trader specifies or clarifies the claim in clear and prominent terms (for example, replacing or clarifying "eco-friendly matchday operations" with wording such as "100% of matchday electricity is sourced from certified renewable energy providers", stated prominently on the same communication or via an easily-accessible link to more detail e.g., QR code).

• Future environmental claims may be misleading if they are not independently verified. Environmental claims relating to future environmental performance may be considered misleading if they are not substantiated with clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan that is regularly verified by an independent third party. That plan must include measurable and time-bound targets and demonstrate the allocation of resources necessary to achieve them. 

  For example, if a national sports federation publicly commits to achieving net-zero emissions by 2035, it would need to support that claim with a detailed, publicly available and independently verified plan (e.g. covering areas such as venue energy use, travel and supply chain emissions) rather than relying on a broad aspirational statement without measurable actions.

• Social characteristics are now explicitly within scope. EmpCo expressly includes "social characteristics" among the main characteristics of a product that must not be misleadingly presented to consumers. These encompass, among other things, the quality and fairness of working conditions (including adequate wages, social protection and workplace safety), respect for human rights, and equal treatment and opportunities. 

  For sports organisations, this means that claims relating to ethical supply chains (for example, fair labour conditions in kit manufacturing), diversity and inclusion initiatives, or community impact programmes will also need to be subject to enhanced governance and controls. 

Bringing it all together: governance, compliance and what organisations should be doing now

With fewer than four months remaining before EmpCo applies, the message for organisations preparing for compliance is clear. Whether the claim relates to a tournament's carbon footprint, a sponsor's sustainability credentials, a kit manufacturer's supply chain practices, or a club's net-zero target, it is more important than ever to be specific and substantiate claims. 

Organisations can prepare by: 

• reviewing their existing communications;

• stress-testing their sustainability claims against the new rules; and

• putting in place robust substantiation and verification processes.

This will not only mitigate regulatory risk but will also ensure organisations are best placed to build strong relationships and take advantage of opportunities with business partners, customers, fans and the wider public. 

It should also be borne in mind that EmpCo is only one player on Team Anti-Greenwashing, with a number of other regimes and drivers meaning that claims should be subject to the increased governance above. Even where EmpCo is determined not to be directly applicable, lessons can be learned from the EmpCo rules and associated guidelines.

Further reading 

For more information on EmpCo, see our:

• client briefing;

• transposition tracker; and 

• webinar. 

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