New guidance on communicating EPDs under the EU Empowering Consumers Directive
In light of the EU Empowering Consumers Directive (EmpCo), which will apply from 27 September 2026, the International EPD System has published guidance on communicating EPDs. The guidance clarifies how EPDs and the International EPD System logotype should be used in consumer-facing communications to avoid implying certification, endorsement or environmental superiority.
From 27 September 2026, the requirements of the EU Empowering Consumers Directive (Directive (EU) 2024/825), known as EmpCo, will apply across the EU. The Directive introduces new requirements for environmental claims and sustainability labels in consumer-facing commercial communications, including restrictions on certain generic environmental claims such as “green” or “environmentally friendly”.
These requirements are closely relevant to manufacturers and LCA consultants working with the International EPD System (IES), as well as verifiers performing EPD verifications and other market professionals using EPD-related information in consumer-facing communications. Organisations should review how they refer to EPDs and how they use the International EPD System logotype in such communications.
International EPD System's position
It is important to distinguish between an EPD itself and how an EPD, its information or related graphics are used in marketing and other communications.
A neutral IES EPD document does not, in itself, constitute a green claim or sustainability label. An EPD provides quantified and independently verified environmental information, and does not state that a product is sustainable or environmentally preferable, certified or endorsed.
However, logos, trust marks and other EPD-related graphics used in consumer-facing product communications may require separate assessment under the sustainability-label provisions of Directive (EU) 2024/825.
The International EPD System logotype identifies the programme under which an EPD is published. Within the EPD document, its purpose is programme identification and traceability. It does not indicate that the product or manufacturer is certified or endorsed by the International EPD System, nor does it imply that the product is environmentally superior, green, sustainable or climate-friendly.
Guidance for EPD communications
To support clear and neutral communication:
Retain the International EPD System logotype on published EPDs as required by programme rules.
Use neutral and factual references to EPDs. For example: “This product has a published, independently verified Environmental Product Declaration (EPD). View the EPD in the EPD Library.”
Do not detach the general International EPD System logotype from its programme-identification context and use it as a product merit badge.
Do not describe the logotype as an ecolabel, quality seal or product certification, or as proof that a product or organisation complies with EmpCo.
Organisations using EPDs in consumer-facing communications are encouraged to review their current practices ahead of 27 September 2026 and assess whether EPD references, logotypes and related environmental claims are presented appropriately.
Note: This guidance reflects the International EPD System’s position on the use and communication of EPDs and does not constitute legal advice. Organisations remain responsible for assessing their communications against applicable EU and national requirements.
