The EU Empowering Consumers Directive: What it Means for You

Not yet from our side. Until March 31, 2027, we recommend it but don't require it, and we'll keep approving artwork without it. Remember that EmpCo itself applies from September 27, 2026. If you sell in the EU, adding the text sooner reduces your legal risk.

Only if your products use mass balance or, for products sold in the EU, contain less than 100% certified content. Until March 31, 2027, we recommend the new disclosure text, but we don't require it. From April 1, 2027, any new print run needs it. The text can go on the back of pack and does not need to be placed under the seal, so in most cases this is a small change at your next artwork update.

We strongly recommend including the new disclosure text now. We will still approve artwork without it until March 31, 2027. However, packaging designed without it cannot be reprinted after that date, and for products sold in the EU it carries legal risk under EmpCo.

Yes. From our side, packaging printed before April 1, 2027, can be used until stock runs out. You just can't print new packaging with the old artwork. EmpCo applies separately to products sold in the EU. See "Existing stock under EmpCo" above.

Until March 31, 2027, yes. From April 1, 2027, approvals without the required disclosure text expire, whatever end date is on the letter. Please update the artwork and resubmit it.

It depends on which one it is.

• Claims: if there isn't enough space to sufficiently specify a claim on the same medium, don't use the claim.

• Mass balance and certified-percentage disclosures: if your product uses mass balance, or is sold in the EU with less than 100% Rainforest Alliance Certified content, you need the relevant disclosure text to use a Rainforest Alliance seal. Text can go on the front or back of pack and does not need to be placed under the seal.

In both cases, QR codes, the QR-code seal and links can give consumers more information. But these don't replace the requirement to include mass balance and certified-percentage texts when applicable. If space is a real problem, please talk to us before you decide to remove the seal. We'd rather help you find a solution.

EmpCo applies to commercial practices aimed at consumers in the EU. What matters is where a product is marketed and sold to consumers, not where it is made. Products made in the EU and sold only outside it are therefore not covered by the EU-only certified-content disclosure.

However, the other changes apply in every market:

• Predefined claims: use the updated claims wherever you sell.

• Mass balance disclosure: required for mass balance products in all markets.

• Level A remote audit: required for all Certificate Holders with sites in verification level A, wherever they are based or sell.

For a summary of each change, see the table above.

Yes. Mass balance is still a valid traceability model in our program, and EmpCo does not prohibit it. The change is that consumers must be told what mass balance means. A mass balance product must not suggest that the ingredient physically in the pack is certified.

EmpCo requires clear, specific claims, and guidance from the National Advertising Division in the United States has found that mass balance confuses consumers and recommended an explanation on pack. One global requirement also means one pack design can serve every market.

Under EmpCo, Rainforest Alliance seals can only be displayed in the EU if they are based on a certification scheme. To qualify as one, a scheme must verify all its Certificate Holders through an independent third party. Endorsements do not meet this requirement, so level A Certificate Holders now need an audit.

The requirement applies globally because EmpCo assesses the certification scheme as a whole. If any of our Certificate Holders, anywhere in the world, were not independently verified, the Rainforest Alliance would not qualify as a certification scheme, and our seals could no longer be used in the EU.

Consistent verification across all markets also strengthens the traceability data that retailers and brands increasingly ask for. Affected Certificate Holders have until December 31, 2027, to complete their first audit.

EmpCo raises the bar for environmental claims. A claim must explain exactly what it refers to, on the same medium, or it risks being deemed misleading. We have updated our predefined claims to meet that standard, and they are now more detailed as a result.

Our predefined claims are in Appendix C of the Labeling and Claims Policy. You can find more guidance in How to Talk About Your Work with the Rainforest Alliance.

Only for what certification actually verifies. Certification can support claims about compliance with specific requirements in our standards, and about certified sourcing that can be verified through our traceability system. It cannot substantiate broad, comparative or outcome-based environmental claims.

• Can be supported: "80% of the cocoa we source is Rainforest Alliance Certified." Traceability data in our system can verify this claim.

• Cannot be supported: "Our cocoa protects rainforests" or "Our chocolate is better for the environment." These claim outcomes or comparisons that certification does not measure.

No. Rainforest Alliance certification should not be used to support broad or absolute claims such as "sustainable", "green" or "eco-friendly". Certification demonstrates compliance with specific environmental and social requirements for a defined scope; it does not demonstrate overall environmental performance.

Under EmpCo, a generic environmental claim is an environmental claim whose specification is not provided in clear and prominent terms on the same medium. For example, "eco-friendly" on a pack, with no explanation on that pack of what it means, is a generic claim. Generic environmental claims are prohibited unless the company can demonstrate "recognized excellent environmental performance" relevant to the claim. In practice, this can only be shown through the EU Ecolabel, an officially recognized EN ISO 14024 type I ecolabel, or top environmental performance under other EU law. Because Rainforest Alliance certification does not fall into these categories, we advise making all environmental claims as specific as possible.

EmpCo bans environmental claims related to future environmental performance without clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan that includes measurable and time-bound targets and other relevant elements necessary to support its implementation, such as allocation of resources, and that is regularly verified by an independent third-party expert, whose findings are made available to consumers.

No. The definition of "generic environmental claims" provided by EmpCo explicitly excludes claims included on a sustainability label. However, these words may still be considered an "environmental claim" and are therefore subject to the requirements of the Unfair Commercial Practices Directive, meaning they must not be misleading. They should not be expanded or interpreted in marketing communications as guarantees or proven outcomes beyond what the certification standards and verification system actually cover.

When we review claims, we check that they follow our Labeling and Claims Policy and use our predefined claims correctly. We do not check whether a claim complies with EmpCo or with national law.

No. Our certification program meets EmpCo's definition of a certification scheme, and our predefined claims are designed with EmpCo in mind. Each product and communication is still the responsibility of the company making the claim, and national laws may add requirements. We recommend you get your own legal advice.

The company making the claim to consumers, usually the brand owner. The Rainforest Alliance provides guidance and predefined claims, but it does not give legal approval or take responsibility for company claims.

EmpCo is an EU law adopted in 2024 that strengthens consumer protection rules against misleading environmental claims. It amends the Unfair Commercial Practices Directive (UCPD). EmpCo generally prohibits generic environmental claims, and it bans sustainability labels that are not based on a certification scheme as the Directive defines one. It aims to improve transparency, credibility and consumer trust in sustainability communication across the EU market.

EmpCo applies from September 27, 2026. It covers all consumer-facing commercial practices in the EU, including packaging, websites, marketing materials and advertising.

The Directive has no transition period. In principle, all products on shelf and all consumer-facing communication must comply from September 27, 2026. In its “Common Understanding on Old Stock Situations” (June 2026), the European Commission indicated that authorities may take account of genuine and specific difficulties companies face during the transition. Companies are advised to engage with relevant competent authorities in this case. For practical options for existing stock, see "Transition and existing stock" above.

Comparative environmental claims are allowed only if they are clear, fair and based on equivalent and verifiable data. Vague comparisons such as "more sustainable" or "better for the environment", without explaining the basis for comparison, are high risk and not supported by certification alone.

Under EmpCo, a certification scheme is a system that uses independent third-party verification to confirm that a product, process or business meets defined sustainability requirements, among other criteria as set out in the definition provided in the Directive. From September 27, 2026, sustainability labels that are not established by public authorities may only be used if they are based on such a certification scheme. This ensures that sustainability claims shown to consumers are credible, transparent and independently verified.

The Rainforest Alliance Certification Program, covering both our Sustainable Agriculture Standard and our Regenerative Agriculture Standard, meets these criteria. Our certification system is based on:

• Publicly available requirements, set out in our standards

• Independent third-party audits conducted by accredited certification bodies

• Ongoing monitoring and verification of compliance, in line with recognized international standards

• Transparency, credibility and fairness, including clear rules for participation and use of Rainforest Alliance certification seals

• Development of requirements through consultation with experts, stakeholders, farmers, companies and civil society

Read more in Meeting the EmpCo requirements with Rainforest Alliance Certification.

Not directly. EmpCo amends the rules on business-to-consumer practices. However, information you share with business customers often reaches consumers, so we recommend using the same predefined claims throughout.