From 27 September 2026, the rules of the EmpCo Directive ((EU) 2024/825) apply, classifying environmental claims made without evidence as unfair commercial practices. Audit experience shows unsubstantiated "green" labels can still be found on store shelves — often with more promised on the localised label than on the original.
"97% ingredients of natural origin," claimed the label of a shampoo imported from Germany; its ingredient list could not substantiate the claim. On top of that, the Hungarian label version carried a "carbon neutral" claim that did not appear on the German original. "A claim like that raises the chance the consumer takes the product off the shelf — but if it is ever challenged, the manufacturer will most likely be unable to prove it," says Zsolt Takács, owner-CEO of ESGinfo.hu and ReadyPass, who regularly encounters similar cases on manufacturer and distributor audits: claims like "80% eco-friendly packaging" or "made from 100% recycled material" turn up from toilet paper through cosmetics to fruit drinks — without adequate substantiation.
Ignorance, not conspiracy
According to the expert, greenwashing is in most cases not deliberate fraud. "The most common cause is lack of awareness and attention: non-specialists — marketing or packaging design — add good-looking green labels without knowing that a burden of proof comes with them. Some know the product isn't quite that, but they also know the customer buys it if it's printed on the box. Deliberate, bad-faith deception is the rarest," says Zsolt Takács. And that is exactly the difficulty: the bad-faith actor is quickly exposed, while lack of awareness can only be dismantled through education and genuine verification of supplier declarations. There is a fresh example of the latter as well: a review is currently under way in which the truthfulness of an Asian supplier's product declaration has to be verified by an external expert.
How large are the fines?
The sanction regime for green claims is still taking shape at member-state level, but sustainability regulation already offers a reference point: failing to meet ESG reporting obligations can draw a fine of up to 1% of revenue, and up to 3% for accumulated infringements. "For a company with HUF 100 million in revenue, a 3-million-forint fine certainly takes half the profit. At a serious company, the managing director will be held accountable for a fine like that," the expert illustrates the magnitude.
What should companies do by 27 September?
The expert recommends five steps: (1) a claim inventory across every surface and every language variant; (2) evidence for every claim — measurement, certificate, documented calculation; (3) validation of supplier declarations; (4) structured, trusted storage of the supporting data — this is what the digital product passport (DPP) is for, publishing the data electronically signed and verifiable; (5) whatever cannot be proven comes off the product. "That is the cheaper solution compared to the fine — and far cheaper than the reputational damage," adds Zsolt Takács.
About the publishers
ReadyPass (readypass.eu) is a Hungarian-built digital product passport platform: it makes the data behind environmental claims available in a structured form, with eIDAS-compatible electronic signatures, verifiable via QR code. ESGinfo.hu is a sustainability consultancy and knowledge portal supporting companies with audits, training and ESG reporting advisory.
Press contact
Szabolcs Filep — ReadyPass · Contact form
Zsolt Takács — ESGinfo.hu · Contact form
Interviews, background briefings and further audit cases can be arranged.
This press release may be republished freely, in full or edited, with attribution to the sources (ReadyPass, ESGinfo.hu).