The automotive industry faces unique challenges under the new EU Green Claims and EmpCo Directives (see our earlier TWheel-FAQ here). As one of the most scrutinized industries in terms of environmental impact, manufacturers and suppliers must take proactive steps to ensure compliance while maintaining competitive sustainability messaging.
While our earlier FAQ (see Part 1 here) dealt with general considerations throughout businesses, the following Part 2 shall serve as a starting point for automotive-specific review and analysis:
1. Why do these changes matter for the Automotive Industry?
The upcoming regulations will significantly impact how OEMs (Original Equipment Manufacturers), suppliers, and dealers communicate their sustainability efforts. It is to be expected that Green Claims must be:
- Scientifically substantiated – No more vague terms like "eco-friendly" or "green mobility" without hard data. Transparent about emissions reductions – Offsetting will no longer be enough to justify claims like "climate-neutral car."
- Independently verified – Claims must be approved by external bodies and updated every five years.
Companies failing to meet these standards stand to risk lawsuits, regulatory penalties, and reputational damage—not just from authorities but also from competitors and consumer protection groups.
2. What should I consider with regard to vehicle advertising & marketing?
Many car manufacturers and dealers use environmental claims to differentiate their products, but the new rules could mean that:
- Misleading or vague claims (e.g., “zero-emissions” for plug-in hybrids without lifecycle analysis) will be prohibited.
- Offsetting-based claims (e.g., "net-zero fleet by 2030") must specify actual reduction measures, not just carbon offsets.
- General eco-labels (e.g., a "green car" badge) will require strict scientific validation.
What to do instead:
- Ensure all sustainability claims (e.g., CO₂ reductions, fuel efficiency improvements) are backed by verifiable scientific data.
- Clearly define the scope of the claim—does "climate neutral" apply to the entire vehicle lifecycle, just production, or just driving emissions?
- Adjust consumer communications to be more educational, detailing the actual environmental impact of each vehicle.
3. Should I also inspect my Supply Chain? Must I consider Compliance-rules?
Car manufacturers rely on complex global supply chains, so upcoming regulations will require full transparency about the environmental impact of suppliers. Risk areas include:
- Suppliers may use unaudited sustainability claims that could expose OEMs to liability.
- Lack of traceability in emissions data from battery, steel, and electronics production.
- Existing offset-based sustainability strategies may no longer meet EU standards.
What to do instead:
- Conduct supply chain audits to ensure all sustainability claims (e.g., “low-carbon steel,” “recycled materials”) are verifiable.
- Require suppliers to certify their environmental impact and comply with EU Green Claims rules in contracts.
- Develop standard reporting requirements for emissions data throughout the entire supply chain.
4. Any specific thoughts on EVs & Lifecycle Assessments (LCA)?
EVs (electric vehicles) are marketed as sustainable solutions, but regulators could require companies to prove these benefits with full lifecycle data.
One key risk: Simply stating “zero emissions” will no longer be sufficient—companies must disclose battery production emissions, mining impacts, and electricity grid factors.
What to do instead:
- Adopt lifecycle assessments (LCA) for all models—clearly showing total emissions, from production to end-of-life.
- Be specific in marketing materials, e.g., “this EV emits 60% less CO₂ over its lifetime compared to a diesel vehicle, based on a certified LCA.”
- Clarify local charging emissions, as grid energy sources impact real-world EV sustainability.
5. Is this also going to be a dealer & aftersales problem?
Yes. Car dealerships and service centers often use Green Claims to attract customers. However, under the EmpCo Directive, even dealer-level advertising will be strictly regulated. Key risk areas to be considered:
- Unverified efficiency claims (e.g., “hybrid model saves 30% fuel” without clear testing conditions).
- Overstating eco-benefits of maintenance services (e.g., "eco-friendly car wash" must specify how it reduces water use).
- General sustainability branding (e.g., "eco-certified dealership") without third-party validation or through self-appointed sustainability label(s).
What to do instead:
- Train dealers on compliance—ensure sales and marketing teams understand what they can and cannot claim.
- Update brochures, websites, and advertising to reflect only verified environmental claims.
- Ensure all fuel consumption and CO₂ figures are based on regulated testing procedures (e.g., WLTP cycle, not outdated NEDC figures).
6. What timelines must I consider, and what next steps should I take?
Key deadlines are:
- By September 27, 2026: Full compliance with the EmpCo Directive across all EU member states.
- Green Claims Directive finalization: Expected shortly after, with an additional implementation period.
- No "grandfathering" period: Existing campaigns and product lines will not be exempt from new rules.
Action Plan for Automotive Companies:
- Review all sustainability messaging—ensure claims comply with upcoming EU rules.
- Audit supply chain partners—require clear emissions and sustainability data.
- Develop lifecycle assessments (LCA) for all models—prepare for stricter reporting.
- Educate marketing and sales teams—train staff on permissible claims and compliance.
- Adapt contracts and supplier agreements—reduce liability for third-party claims.
