Environmental claims in sport: What the EU’s EmpCo Directive means for clubs, sponsors and broadcasters
A new European Union regulation has recently come into effect to help ensure that sustainability claims are credible and consumer-friendly and raise the bar for how such claims are communicated.
This article explores what this new legislation, the EU Directive on Empowering Consumers for the Green Transition[1] (also known as the “EmpCo” or “ECGT” Directive) means for sports organisations, sponsors, licensees and broadcasters and others and how organisations can get ahead of the game now that the requirements have begun to apply. Although the Directive was adopted in 2024, Member States were required to transpose it into national law by 27 March 2026 and apply the resulting measures from 27 September 2026, which is why it is now a live compliance issue.[2]
It looks at:
- Why environmental claims matter in sport
- Enter the EU’s Directive on Empowering Consumers for the Green Transition
- How is EmpCo reshaping the playing field for sports organisations?
- Certain carbon offset-based neutrality claims on products are banned
- Generic environmental claims to be based on recognised excellent environmental performance
- Future environmental claims need to be supported by publicly available and verifiable commitments and targets
- Social characteristics are now explicitly within scope
- Bringing it all together: governance, compliance and what organisations should be doing now
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Written by
Claudia Harper
Claudia is an Associate in Linklaters' Environment and Climate Change practice. She is qualified to practice in England & Wales and Australia.
James Marlow
James is a Managing Associate in the Environment & Climate Change team at Linklaters, with experience advising on a broad range of ESG and EHS matters. He is particularly interested in corporate governance, human rights, crisis management and climate change related issues.
Georgina King
Georgina is a Managing Associate at Linklaters in the Litigation, Arbitration & Investigations practice and a founding member of the firm’s Sports Sector team. She boasts a diverse portfolio of expertise in commercial arbitration, litigation, competition litigation, public law and crisis management. While she has represented clients across various sectors, her primary focus has been on the sports sector, where she advises on complex disputes and regulatory matters.
Georgina’s recent matters include advising:
- the Premier League on its position in relation to the European Super League (ESL) as well as various regulatory, contentious and competition law issues
- the Premier League on its proceedings against a club for breaches of the Profitability and Sustainability Rules
- INEOS Racing Limited on EDM America’s Cup 37 Trustee
- a leading Formula One team on its most significant sporting regulatory issues, including their avenues to challenge and appeal decisions
- Relevant Football Partners on the marketing and sale of the commercial rights for UEFA men’s club competitions, including the UEFA Champions League.
- The Football Association and Premier League in relation to their respective investigations conducted into certain historic football transactions which occurred at Chelsea FC under Mr Roman Abramovich's ownership.
Benja Arnott
Benja is a Managing Associate in Linklaters’ Litigation, Arbitration and Investigations practice and a member of Linklaters’ sports sector team. He has extensive experience advising sports governing bodies on competition, public and contract law, governance and regulatory matters, and acting on sports disciplinary proceedings and arbitrations. Benja is also a member of Sport Resolutions’ Pro Bono Panel. Outside of his sports practice, Benja’s practice also covers ESG, human rights, public international law, public law and competition law matters.
