DVSI Calls for Practical Adjustments to the EmpCo Directive

DVSI is advocating for practical adjustments to the EmpCo Directive, including a transition period that prevents unnecessary product waste and economic harm while preserving the directive’s sustainability goals.

The Empowering Consumers for the Green Transition Directive (EmpCo Directive) is part of the European Green Deal and aims to strengthen consumer protection against misleading environmental and sustainability claims. In the future, sustainability-related statements must be substantiated and legally compliant. The directive is scheduled to take effect on 27 September 2026.

DVSI supports the European Commission’s objective of ensuring that environmental claims used in marketing and on product packaging are transparent and understandable for consumers. However, the association is concerned that the transposition of the directive into national law could lead to fragmented implementation across Member States. From DVSI’s perspective, one of the most critical shortcomings is the complete absence of transitional provisions for products that have already been manufactured or are already available on the market.

DVSI, together with other consumer goods associations such as the Markenverband and the German Association for Writing, Drawing and Creative Design Industries, considers such a transition period essential to avoid undermining the directive’s intended purpose. It cannot be the objective of the directive to remove durable, high-quality branded products from store shelves solely because they were labelled according to previous requirements. Such an outcome would contradict the very principles of sustainability. In addition, many toys and their packaging are planned and produced well in advance.

DVSI has been discussing this issue with policymakers for some time, including representatives of the German Federal Ministry of Justice and Consumer Protection, members of the German Bundestag, and German Members of the European Parliament. The association is also engaged in intensive dialogue with retailers, who generally place responsibility on manufacturers and suppliers. DVSI’s position is shared by others: the German Bundesrat has also called for measures to prevent unnecessary product destruction and significant economic losses. At the same time, the Bundesrat points out that the German government sees little room for manoeuvre in implementing the directive due to EU deadlines.

According to sources in Brussels, a coordination group has been established to develop a balanced solution that preserves the directive’s objectives while avoiding economic damage for companies. In February 2025, the European Commission announced its intention to strengthen the economy and reduce administrative burdens. If the EmpCo Directive were implemented in German law without any transitional arrangements, it would have far-reaching consequences for toy manufacturers as well. Discussions in Brussels are ongoing, and further adjustments may emerge in the coming weeks. Toy Industries of Europe (TIE) and its national member associations, including DVSI, remain actively engaged and will continue to keep members informed.

Your contact at DVSI: Ulrich Brobeil, Managing DirectorT: +49 911 477112-11E: brobeil@dvsi.de