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Publishing Your Protein Ratio Without Greenwashing Risk: What the EmpCo Directive Changes
By Romain Balès and Dexter Oelrichs
The EU's EmpCo Directive applies from 27 September 2026 and sets stricter rules for environmental claims made to consumers. A protein ratio shown in store, on a website or in a campaign can be one of them. It can still be published, provided it is precise, explained and verifiable. Here is what the text says, where France stands, and our rules for publishing safely.
What is the EmpCo Directive?
Directive (EU) 2024/825, known as EmpCo (for "Empowering Consumers"), strengthens consumer protection against greenwashing. Adopted on 28 February 2024, it amends two existing texts: the Unfair Commercial Practices Directive and the Consumer Rights Directive.
Its timetable is set: Member States had to transpose it by 27 March 2026, and the new rules apply from 27 September 2026. There is no transition period: they also cover claims and labels already in circulation.
Is a protein ratio an environmental claim?
In many cases, yes, as soon as it is addressed to consumers.
The directive defines an environmental claim broadly: any non-mandatory message or representation, in any form (text, image, graphic, symbol, brand or product range name), that states or implies that a product, brand or trader has a positive or zero impact on the environment, is less damaging than others, or has improved its impact over time.
A protein ratio does not talk about the environment directly. But shown to customers as progress towards more plant-based food, it often implies an environmental benefit. In our reading, it then falls within the scope of the directive.
Context matters:
- A figure published in a sustainability report aimed at investors falls first under non-financial reporting, a different framework from commercial practices.
- The same figure reused in store, on the online shop, on packaging or in a campaign becomes a commercial communication addressed to consumers, and therefore a potential claim.
What the directive prohibits
The directive adds several practices to the list of those banned in all circumstances. Four of them bear directly on publishing a protein ratio.
Unsubstantiated generic claims. Terms such as "environmentally friendly", "green" or "climate friendly" are banned unless the trader can demonstrate recognised excellent environmental performance. A claim is no longer generic when its scope is specified clearly and prominently on the same medium.
Uncertified sustainability labels. A label is only allowed if it is based on a certification scheme with monitoring by an independent third party, or if it is established by a public authority. A pictogram or badge designed to look like a label can be treated as one.
Claims that go beyond their subject. It is forbidden to present a claim as applying to a whole product or a whole business when it only concerns one aspect of it.
Promises about future performance without verifiable commitments. A claim about future environmental performance must rest on clear, public and verifiable commitments, a detailed and realistic implementation plan, and regular verification by an independent third-party expert.
Where does France stand?
On the date of this article, France has not yet transposed the directive.
The transposition text sits in Articles 20 and 21 of the bill on various provisions adapting French law to EU law (known as DDADUE). The Senate adopted it on 18 February 2026, but the National Assembly has not yet examined it. On 28 May 2026, the European Commission sent a letter of formal notice to France and nineteen other Member States for failing to transpose.
In practice, the DGCCRF, the French consumer protection authority, cannot base an enforcement report on the directive alone until it is transposed. But existing rules still apply, starting with the ban on misleading commercial practices. The DGCCRF checked more than 3,000 establishments on their environmental claims in 2023 and 2024.
For a retailer, waiting for the French law would be a poor bet. Transposition can happen at any time, and retailers present in several European countries are already subject to the national laws that have transposed the directive.
How to publish your protein ratio safely: our six rules
These rules turn our reading of the directive into practice, for a ratio calculated under the Protein Tracker or the WWF methodology.
1. State precisely what the figure measures
A published ratio should state its methodology, its basis (protein or tonnes of product), its scope, its period and the share of sales covered. That is what makes it clear and verifiable, and what stops it being read as a general promise.
Rather than: "Our range is increasingly plant-based and sustainable."
Write: "In 2025, 42% of the protein sold in our stores in France came from plant sources (calculated under the Protein Tracker, on 95% of our sales volumes)."
Why these details matter is explained in our overview Protein Ratio: Where Do European Retailers Stand in 2026?: two "plant shares" published by two retailers may measure nothing comparable.
2. Keep the context around the figure factual
A precise figure offers no protection if it is surrounded by generic wording. "Good for the planet" or "responsible range" next to the ratio brings a generic claim back in. The ratio, its methodology and its scope are enough.
3. Write "calculated under", never "certified"
A ratio calculated under the Protein Tracker or the WWF methodology is not certified by those organisations, unless they have actually verified your data. Also avoid dressing the figure up with an in-house badge, logo or pictogram: a factual figure or chart informs, but a sign that looks like a label can be treated as a sustainability label, and would then need to rest on a certification scheme.
4. Present a target as a target
A target can still be published if it is presented as an ambition, not as an achieved result: "our target is to reach 60% plant protein by 2030" rather than "our sales will be 60% plant-based in 2030". Back it with the plan that supports it and regular progress updates. Because claims about future environmental performance are among the most tightly regulated by the directive, have your legal team approve the wording of any target before it is shared with consumers.
5. Do not stretch the figure beyond its scope
A ratio calculated for one country, one banner or part of the range should not be presented as valid for the whole group or every aisle. If departments or sales are excluded, say so.
6. Keep the evidence
If challenged, it is up to the trader to substantiate the claim. Keep the data used, the methodology, the scope statement and the calculation file for each year published. A calculation in which every value carries its source makes that substantiation easier. We describe ours in How Altera Calculates Your Protein Ratio, Step by Step.
Examples of publication
Several European retailers already publish their ratio and name their methodology. Without judging their compliance, two examples illustrate the good practices described above:
- Carrefour Belgium published a ratio of 42.2% plant protein in July 2026, stating that it was calculated under the Protein Tracker.
- REWE and PENNY in Germany state that their 54% figure covers the volumes of their whole range excluding drinks, measured on the basis of the WWF methodology, and present their 60% figure for 2035 as a target.
What about the Green Claims Directive?
A second directive, known as Green Claims, had been proposed to govern the substantiation and prior verification of explicit environmental claims. It is currently suspended, without having been formally withdrawn. The EmpCo Directive has been adopted and applies regardless of what happens to it.
Frequently asked questions
Can we still publish our protein ratio?
Yes. The directive does not ban publishing a figure: it requires the figure to be precise, understandable and verifiable, and not presented in a misleading way.
Do we need to have our ratio certified?
Not to publish a factual figure together with its methodology. Certification becomes necessary if you want to display a label, or a sign that looks like a label.
Does this apply to a sustainability report?
The directive targets commercial communications addressed to consumers. A figure published in a sustainability report falls first under other rules, but if it is reused in store, on packaging or in a campaign, it becomes a claim.
Can Altera certify our ratio?
No. Altera Food Initiative calculates your ratio under the Protein Tracker and the WWF methodology: it does not certify it. It does, however, provide what you need to substantiate it: a line-by-line file with the source of every value, and a scope statement.
Conclusion
EmpCo does not make publishing a protein ratio riskier for those who do it properly. Above all, it makes vague messages riskier. A precise ratio, with its methodology and scope explained and a calculation that can be traced, is exactly the kind of information the directive aims to encourage.
Before publishing, then, you need a solid calculation. That is one of the topics we cover in 10 Questions Retailers Ask Before Calculating Their Protein Ratio.
Altera Food Initiative calculates retailers' protein ratios free of charge, under the Protein Tracker and the WWF methodology, with the source of every value and a scope statement. Discover the tool · Contact us
Sources
Directive (EU) 2024/825 of 28 February 2024 on empowering consumers for the green transition (EmpCo).
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L0825
Latham & Watkins, EU Empowering Consumers Directive: New Rules on Green Claims Apply From 27 September 2026, September 2026.
Victoris Avocat, Allégations environnementales : ce que vous ne pourrez plus écrire à partir du 27 septembre 2026, September 2026 (status of transposition in France).
https://www.victorisavocat.com/blog/allegations-environnementales-27-septembre-2026-directive-empco
R3, Directive ECGT (2024/825) : ce qui change pour votre communication RSE en 2026, August 2026 (DDADUE bill, letter of formal notice, DGCCRF checks).
https://www.r3.fr/ressources/directive-ecgt-nouvelles-regles-communication-environnementale
Données personnelles, Allégations environnementales : ce qui change en 2026, August 2026 (DGCCRF powers before transposition).
https://www.donneespersonnelles.fr/allegations-environnementales
Projet Celsius, EmpCo (UE 2024/825) et Green Claims : ce qui change en 2026 pour les marques, June 2026 (status of the Green Claims Directive).
https://projetcelsius.com/blog/communication-environnementale-cadre-france-europe-2026/
RetailDetail, Carrefour Belgium shares its progress on the protein shift, 15 July 2026.
REWE Group, Vielfalt für eine bewusste Ernährung.
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