The European rules for sustainability claims have been tightened considerably, with the Empower Consumer Act (EmpCo) as the latest step, which applies across the EU from 27 September 2026. At nearly every company, that raises the same question: is this still allowed? Sustainable on the packaging, climate neutral in a campaign, your own green logo on the website. The answer is in the law and in the ACM’s Guidelines on Sustainability Claims, but you do have to hold those up against your own claim. We wanted to save you that step. That’s why we built Empact’s Greenwashing Check: free, no account needed, and without having to commit to a consulting process right away.
Keep telling what you do
The reaction we see most often is caution: if it’s that strict, we’d rather not say anything about sustainability at all. In our view, that’s a shame. Dutch businesses are becoming more sustainable and are entitled to show it. The rules target the vague slogan without evidence; a concrete claim you can substantiate is allowed. Which phrases are affected and how to say it instead is in our article on the seven claims that are no longer allowed. The check is there for the next step: your own claim.
The AI reads, the rules decide
What makes it special is the setup. You enter your claim as a photo of the packaging, as a link or as text. The AI reads what it says, who it’s aimed at and which questions matter for this claim. The verdict comes from a fixed set of rules we built into it: the European bans from EmpCo and the ACM’s Guidelines on Sustainability Claims. The AI can’t change those. If your product is also subject to its own rules, such as cosmetics or packaging, the check points that out. What’s more, a claim only turns red based on an answer you gave yourself; if you don’t know something, that point is left untested.
Before we opened up the check, we ran 63 claims through it that the ACM, a court or the Dutch Advertising Code Foundation had already ruled on: 31 examples from the ACM guidelines and 32 claims from real cases, from aviation to clothing and supermarkets. We knew the verdict, the check did not. Not a single misleading claim got through, and not a single permitted claim was wrongly rejected.
What the check does for you
- Extracts the claims from your photo, page or text and goes through them with you one by one in a single session.
- Only asks the questions that matter for your claim, about the claim itself and about the evidence you have.
- Gives a verdict per criterion with the legal basis, the article of the law or the page from the ACM guidelines, so marketing and ESG are looking at the same document.
- Places the outcome in one of three categories: no longer allowed, needs substantiation, or passes the first test.
- Where needed, suggests a wording that does hold up.
What the check doesn’t do
The check doesn’t see your evidence. Life cycle assessments, certificates and annual reports stay out of view, so whether the figure behind your claim is correct is not something the check assesses. That’s also why it never approves a claim. Whether a claim is misleading is determined by the regulator and the courts, and it obviously doesn’t provide legal advice on your situation. See it as the first step: afterwards, you know which rules apply to your claim and which evidence you need to be able to show.
Who is the check for?
For anyone who communicates about sustainability to consumers, from marketing to the ESG advisor who manages the evidence. And for consumers too: anyone who comes across a claim in a store or online shop and wonders whether it’s true can enter it the same way. If the outcome raises questions, the check drafts a question to the company for you, which is only sent after you have confirmed it.
Why free?
Our goal is to enable companies to do business more sustainably, and part of that is making knowledge accessible. More and more sustainability rules are on the way, and rightly so. The risk is that companies put all their time into compliance and give the actual transition less attention. In our view, AI is the way to handle that compliance well, so that time and money are left for doing business more sustainably. After the DPP Tool and the PPWR Tool, the Greenwashing Check is our third free AI tool.
Getting started
Grab a package, a product page or the line from your latest campaign and enter the claim. If you then want to move on to the evidence behind your claims, we’ll be there to help you as your ESG advisor.
Try the check: tools.empact.nu/en/greenwashing-check