Greenwash controls

Strengthening Transparency and Credibility in Sustainability Communication

The Empowering Consumers Directive (EmpCo) is an EU directive aimed at strengthening consumer protection and combating misleading environmental and sustainability claims. The directive introduces stricter requirements for how companies communicate sustainability information and market environmental attributes of their products, services, and operations.

For many companies, this means sustainability communication needs a clearer link to underlying data, processes, and documentation. Environmental claims must be clear, verifiable, and based on reliable information, while companies also need to ensure internal processes are in place for quality assurance, approval, and monitoring of sustainability-related communication and marketing.

BDO helps companies develop structures and ways of working to strengthen the transparency and credibility of their sustainability communication. This work can include reviewing climate and environmental claims, analysing the underlying data and methodology, and assessing how sustainability-related information is communicated, for example, in reports, marketing, investor dialogue, and customer communication.

We also support organisations in developing internal processes and clear allocation of responsibility related to sustainability communication and "greenwash controls." For many companies, the work centres on creating better coordination between the sustainability function, marketing, legal, product development, and management, to ensure that external communication is consistent, transparent, and well-substantiated.

Common Challenges in Working with the EmpCo Directive

• Ensuring consistent and traceable data 
  Companies often need to develop more structured ways of collecting, documenting, and quality-assuring environmental data so that it can withstand scrutiny and support external communication. In many organisations, data is scattered across different functions and systems, which can make it difficult to ensure traceability and consistency in sustainability-related claims.
• Integration into existing processes 
   Adapting communication, product development, and reporting to meet the new requirements often calls for new ways of working and greater internal coordination. For many organisations, this means integrating sustainability-related controls into existing processes for marketing, product development, risk management, and the approval of external communication.
• Documentation and evidence requirements 
  Substantiating environmental claims typically requires a more systematic approach to documentation, methodology, and supporting evidence. Many companies find it challenging to determine what level of evidence is sufficient and how to communicate sustainability-related claims clearly and proportionate, without creating a risk of greenwashing.