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Communicating the circular economy: the new rules for environmental claims

From 27 September 2026, stricter regulations on environmental claims and sustainability labels will come into force in Austria. With the implementation of the EmpCo Directive, existing requirements for environmental communication will be clarified and supplemented by new prohibitions. This raises the following question for businesses: How can sustainability and circular economy performance continue to be communicated in a way that is clear and easy to understand – whilst remaining transparent, verifiable and compliant with regulations?

This was precisely the question addressed by the Circular Economy Forum Austria’s webinar on 23 September 2026. The focus was on two aspects: the legal framework and its implementation in Austria, and how to deal with the new requirements in business practice. 

What changes will EmpCo bring about?

Alexandra Ciarnau, partner at DORDA Rechtsanwälte and president of Women in AI Austria, provided an overview of the new legal provisions. In doing so, she made it clear that environmental and sustainability claims had previously been subject to the general prohibition on misleading advertising. The EmpCo now introduces specific prohibitions, thereby also making enforcement easier in certain areas. 

Of particular relevance are general environmental statements such as „green“, „ecological“ or „climate-neutral“. Such claims must be properly substantiated and must not be applied across the board to an entire product or company if they actually relate only to individual components, processes or activities. Further regulations concern, amongst other things, claims regarding greenhouse gas emissions, durability and repairability, as well as sustainability labels. In particular, unverified „fictitious labels“ will be significantly restricted in future. 

Statements about future environmental performance must, in future, be clear, objective and verifiable by the public, and must be based on a specific action plan. 

The key message is that there were already many requirements in place regarding verifiable and non-misleading environmental communication. EmpCo is now drawing the lines even more clearly in certain areas.

From general claims to specific statements

The following demonstrated how the new requirements can be put into practice: Maria Leichtfried from the Green Strategy & Marketing team at gugler* DruckSinn.

To this end, gugler* first analysed the existing communications strategy, then sought internal and external expertise, prioritised measures and implemented them step by step. Maria Leichtfried summarised the practical approach to existing environmental statements in five steps: add to, amend, delete, document and communicate.

As a result, general statements are now made more specific and backed up with verifiable information. Rather than simply referring to something as „climate-friendly“, for example, the specific performance behind the claim is described. At the same time, brief claims that could not be adequately substantiated and the company’s own labels have been removed. Internal documentation links the environmental claims used to the relevant evidence and helps staff to use them confidently in their communications. 

Communicate more clearly rather than communicate less

In conclusion, both experts agreed that the new requirements can also present opportunities: for greater transparency, clearer statements and a clearer distinction between environmental benefits that have actually been delivered.

The key takeaway from the webinar: The new rules do not necessarily have to lead to less communication about sustainability and the circular economy. What is crucial is, to communicate in a more specific, clear and verifiable manner.

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The Circular Economy Forum Austria is Austria's largest independent multi-stakeholder platform for the promotion of the circular economy. The forum supports companies and their environment on the path to the circular economy and connects key players to create innovative value creation cycles. The creation of value creation cycles that address social and environmental challenges requires a systemic approach.
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