The deadline to meet the EU’s EmpCo Directive is approaching. Suston checked in with Deuter and Rab to hear how they’re keeping up with the timeline.

All EU Member States were required to transpose the EmpCo Directive into national law by March 27, 2026, and must apply the new rules from September 27, 2026. In key outdoor markets including Germany, Italy, and Austria, national legislation has already been adopted. Brands selling to consumers in these countries must therefore be prepared to meet the new requirements.

Suston Magazine reached out to Christina Völlinger at Deuter and Debbie Read at Rab to find out how they have prepared, and what the process has meant for their sustainability communication.

In short, what has your preparation process looked like?

Christina Völlinger, Deuter: We started preparing for EmpCo compliance early in 2026 and teamed up with NORR agency as they are very experienced when it comes to responsible B2C communication. Together, we developed internal guidelines, working through several iteration rounds across our CSR and marketing teams. We also engaged with external partners such as Bluesign, Green Button and Fair Wear Foundation (FWF) to align our communication with their updated communication rules.

The result was our internal deuter Communication Guidelines for EmpCo, which we distributed to all relevant teams internally and externally to ensure consistency across all markets. This document is not final though. We explicitly framed it as a living document as we as a brand as well as our partners are still gaining expertise. That said, we expect some upcoming iterations, especially after the EmpCo comes into effect at the end of September.

Debbie Read, Rab: This is not completely new territory for us. In 2023, we launched Rab Material Facts initiative to consumers to improve transparency and provide consumers with clear, accessible information about the materials used in our products. That work has given us a strong foundation, but we’re now evolving it further as legislation develops.

Like many businesses in the outdoor industry, our EmpCo preparation process has involved a lot of learning and interpretation. While the direction of travel is clear, there is still some uncertainty around how certain aspects of the legislation will be applied in practice and what “good” ultimately looks like.

We’ve been reviewing our existing sustainability communications, assessing areas of potential risk, and building internal guidance to help teams make informed decisions. At the same time, we’re actively training colleagues across Marketing, Sales, Product and customer-facing teams so they understand both the risks and opportunities associated with the changing regulatory landscape.

What have been the biggest challenges overall?

Christina Völlinger, Deuter: The biggest challenge is the fundamental ambiguity of EmpCo compliance. Unlike many regulatory frameworks, there is no simple checklist or clear black-and-white answer to whether a specific piece of communication is compliant or not. Every claim, every product description, every label has to be assessed individually, weighing the context, the audience, the placement and the level of substantiation behind it. This requires constant judgement calls, and reasonable people within our own teams – as well as our legal and CSR advisors – do not always arrive at the same conclusion.

This is particularly challenging in a fast-moving marketing environment, where new content is being created continuously across multiple channels, languages and markets. What is considered compliant in one context may not be in another.

Debbie Read, Rab: The biggest challenge has been navigating uncertainty. While everyone agrees that improving transparency and reducing misleading claims is the right objective, there is still ongoing discussion across the industry about interpretation, practical implementation and the evidence required to support certain claims.

As a UK brand operating in a global market, balancing multiple requirements from different markets also brings complexity. Changes in one market are not necessarily recognized in another, especially between Europe and the rest of the world – and brands are trying to juggle different and often opposing requirements in an increasingly intricate supply chain.

Another challenge is balancing simplicity with accuracy. Consumers want clear and understandable information, but sustainability data is often complex and nuanced. The risk is either oversimplifying information which in turn could reduce the message impact, or providing so much detail that it becomes inaccessible. Finding the right balance is something we’re continuing to work through.

Has the process led to any positive changes in how your company communicates sustainability?

Christina Völlinger, Deuter: Yes, definitely. EmpCo has pushed us to be more precise and even more transparent in how we communicate. Broad sustainability claims have been replaced by specific, verifiable statements. We have been working with partners like Bluesign, Green Button and Fair Wear Foundation for a long time and always tried to be as transparent as possible to the consumer what the collaboration entails and why we partnered up with them in the first place. EmpCo makes these partnerships more important than ever as third-party certifications like Bluesign and Green Button provide the verifiable, independent evidence EmpCo demands.

Debbie Read, Rab: Perhaps the biggest positive is that it has encouraged even greater collaboration between teams that may not previously have worked closely together on sustainability communications. Product, CSR, and Marketing all need to come together to ensure communications are accurate and meaningful.

We have also reinforced the importance of evidence-based communication. Rather than relying on broad statements, we’re focusing more on providing specific, factual information that helps consumers understand the attributes of a product and make their own informed decisions. In many ways, this aligns with the principles behind Rab’s Material Facts programme, which was created to make product information more transparent and easier to understand. The emerging legislation is reinforcing a direction that we have already been working towards for some time.

Do you think the new legislation will help outdoor consumers make better-informed choices? Why or why not?

Christina Völlinger, Deuter: We believe EmpCo has the potential to do exactly that – but only if it is consistently enforced across all markets and across all brands. The directive pushes companies to replace vague “green” claims with verifiable, substantiated information. For consumers who actively seek out this kind of detail, that is a clear improvement. However, for the average consumer the impact may be limited unless sustainability information is made accessible in a way that is easy to find and understand – not buried in CSR sections that many people never visit. The real progress will come when the industry as a whole raises its standards, and when consumers have better tools to evaluate and compare brands. EmpCo is a strong foundation for that – but it is only the beginning.

Debbie Read, Rab: Ultimately, yes, provided it is implemented consistently and accompanied by clear guidance for businesses.

The legislation has the potential to raise standards across the industry by encouraging greater transparency, stronger evidence for claims and clearer communication. That’s a positive outcome for consumers and for brands that are committed to communicating responsibly.

However, legislation alone won’t solve everything. Sustainability is inherently complex, and consumers still need information that is relevant, accessible and easy to understand. Success will depend on whether businesses can translate detailed technical data into clear, meaningful insights without losing accuracy.

If the legislation encourages a shift away from vague environmental marketing and towards more specific, substantiated information, then we believe consumers will be better equipped to make informed choices. That can only be a positive step forward for the industry as a whole.

About EmpCo

The Empowering Consumers Directive, formally Directive (EU) 2024/825, amends existing EU consumer protection law to address misleading environmental claims and labels, commonly known as greenwashing. Adopted on February 28, 2024, and in force since March 26, 2024, it prohibits generic environmental claims, such as “green,” “eco-friendly,” or “sustainable,” unless backed by recognized, verifiable environmental performance.

It also restricts the use of sustainability labels to those based on an approved certification scheme or authorized by public authorities, subject to independent third-party verification. EU Member States were required to transpose the directive into national law by March 27, 2026, with the new rules applying from September 27, 2026.

Read the full EmpCo Directive text.

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Gabriel Arthur
gabriel.arthur@norragency.com
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