Preferred by Nature and EmpCo: supporting credible sustainability communication

A higher bar for sustainability communication

Sustainability claims increasingly need to do more than sound positive. They need to be clear about what is being claimed, specific about the scope, and supported by evidence that can stand up to scrutiny.

The EU Empowering Consumers for the Green Transition Directive (Directive (EU) 2024/825), commonly referred to as EmpCo, strengthens consumer protection rules in this area. It applies from 27 September 2026 and introduces new restrictions on misleading environmental claims and sustainability labels used in consumer-facing communication.

Among other changes, EmpCo restricts unsupported generic environmental claims, sets conditions around claims based on future environmental performance, addresses certain climate-related claims based on greenhouse gas offsetting, and requires sustainability labels to be established by a public authority or based on a qualifying certification scheme.

The direction is clear: environmental communication should be specific, transparent and linked to credible evidence.

How Preferred by Nature is responding

Preferred by Nature works with businesses, producers, land managers, project partners and other organisations in different ways – through certification, advisory services, independent evaluation, projects, training and capacity building. Those relationships differ in purpose, scope and nature, so they should not all be communicated in the same way.

Our approach to EmpCo therefore has two complementary parts:

reviewing and strengthening the rules and assurance arrangements behind certification schemes and certification-related claims, and

establishing clear, organisation-wide principles for how clients and partners may refer to their relationship with Preferred by Nature in external communications.

Preferred by Nature Sustainability Framework Certification

As scheme owner, Preferred by Nature has reviewed the Preferred by Nature Sustainability Framework Certification (PBN SFC) programme in light of EmpCo and the Directive’s definition of a certification scheme. The programme includes a number of elements that address the credibility, transparency and accountability expectations reflected in the Directive, including:

• publicly available certification requirements and defined certification scopes
• standard development and revision processes that include consultation with relevant experts and stakeholders
• procedures for handling non-conformities and for suspending or withdrawing certification and related claim or Seal use where requirements are not met
• independent certification and oversight arrangements designed to support objective monitoring of conformity, and
• dedicated requirements for use of the Preferred by Nature Seal and certification claims, including pre-approved claim options and rules intended to keep communication accurate, transparent and linked to the certified scope.

Together, these elements help link sustainability labels and certification-related claims to defined requirements, assessed performance and verifiable evidence.

Clear communication across all Preferred by Nature relationships

EmpCo is directly relevant to consumer-facing commercial communication, but the principles behind it are useful more broadly: claims should be accurate, proportionate, current and supported by evidence.

Preferred by Nature has introduced an organisation-wide policy for clients, partners and other organisations referring to their work with us in external communications. The policy is designed to make the nature of the relationship clear and to avoid situations where advisory support, project participation, training or another form of collaboration could be mistaken for certification, assurance or endorsement.

The core principles are simple:

• Describe the relationship accurately – for example, whether Preferred by Nature certified, evaluated, advised, trained or collaborated with the organisation.
• Keep the scope clear – do not turn work on one system, project, product category or topic into a claim about an entire organisation or its overall sustainability performance.
• Use evidence – statements should be capable of being substantiated with relevant documentation or verified information.
• Do not imply endorsement – working with Preferred by Nature does not, by itself, mean that Preferred by Nature endorses the organisation, its products or all of its sustainability performance.
• Reflect the actual time period – past work should not be communicated as an ongoing relationship.
• Follow scheme – specific rules where certification claims, labels, trademarks or the Preferred by Nature Seal are used.

The policy also sets out when external communications or use of the Preferred by Nature logo require prior approval, and when a written authorisation agreement is needed.

What this means for clients and partners

Certification clients

Organisations communicating about certification should follow the requirements of the applicable certification scheme, including any rules on claims, labels, trademarks and seal use. A certification claim should accurately reflect what has been assessed and certified and should not extend beyond the certified scope.

Advisory clients, project partners and other collaborators

Organisations may refer to the work they have carried out with Preferred by Nature, but the wording should accurately describe the nature and limits of that work. Advisory support, participation in a project, training or another collaboration should not be presented as certification, product approval or an organisation-wide endorsement unless that type of assurance was explicitly part of the engagement.

Beyond communication: strengthening the evidence behind claims

Credible sustainability communication starts before the wording of a claim. It depends on the practices, systems, data and assurance behind it.

All organisations making sustainability claims

The organisation making a public claim remains responsible for the accuracy and legality of that claim. Certification, evaluation or other work with Preferred by Nature may provide evidence or context, but it does not automatically make every statement about a product, service or organisation compliant with consumer protection law in every EU Member State.

Organisations should therefore consider the following questions before publishing a sustainability claim:

• What exactly are we claiming?
• What part of the product, service, operation or organisation does the claim apply to?
• What evidence supports it, and can that evidence be produced if the claim is challenged?
• Are we describing an achieved and verified result, or a future ambition?
• Are we using a sustainability label or certification claim in accordance with the applicable scheme rules?
• Could the wording create a broader impression than the evidence actually supports?

Beyond certification, Preferred by Nature supports organisations in strengthening areas that can underpin credible sustainability performance and communication, including responsible sourcing, due diligence, traceability, risk assessment, supply chain systems, sustainability strategy, training and capacity building.

These services can help organisations improve the quality of the systems and information behind their sustainability work. They should, however, be described for what they are and should not be presented as certification or independent assurance unless this was explicitly within the scope of the engagement.

We will keep following the evolving regulatory landscape

EmpCo establishes an EU-level framework, while implementation and enforcement will also depend on national law and guidance. Preferred by Nature will continue to monitor relevant EU and Member State developments, including interpretation of generic environmental claims, future environmental performance claims, offsetting and the treatment of business-to-business communication.

We will update our guidance and relevant certification requirements where needed as regulatory interpretation develops.