bluepass and the EU Empowering Consumers Directive

What EmpCo requires of a sustainability label

From 27 September, a sustainability label used on product sold to EU consumers must either be established by a public authority, or be based on a certification scheme. The EU Commission defines a sustainability label broadly: any trust mark, quality mark, or equivalent that distinguishes a product by its environmental or social characteristics. In-house eco-badges and own-brand sustainability tiers fall inside that definition.

Where a label is based on a certification scheme, the directive sets seven requirements for that scheme.

How bluepass meets the seven requirements

1. Certification based on independent third-party verification

Standard setting, assessment, and product certification are separate. bluesign sets the Criteria and conducts the company assessment and product registration. Certification of consumer-facing bluepass Products is conducted by an independent, accredited conformity assessment body: a separate legal entity, with its own reporting lines, its own decision processes, and its own certifiers.

2. The scheme’s requirements and terms are publicly available

The bluesign Criteria and the bluesign Scheme for consumer-facing bluepass Products publish for public consultation this month. Anyone will be able to read them.

3. Compliance monitored by a competent, independent third party

The independent conformity assessment body certifying consumer-facing bluepass Products is accredited to ISO/IEC 17065, the international standard for bodies certifying products, processes, and services. It evaluates every certified product, conducts annual surveillance including product testing, and conducts an oversight assessment of bluesign’s own processes every three years.

4. Transparent, credible, and open on fair and non-discriminatory terms

The certification and evaluation requirements are publicly available. The bluesign Scheme is aligned with ISO/IEC 17067. Every company applies on the same terms.

5. Open to any trader willing and able to comply

Any company willing and able to meet the Criteria can become a bluesign System Partner. There are no exclusivity conditions.

6. Requirements set in consultation with relevant experts and stakeholders

The bluesign Criteria are developed with technical experts and revised through structured stakeholder feedback. The current revision has been through three internal feedback rounds, and publishes for public consultation this month, open to anyone. Independent external experts have had a formal role in safeguarding bluesign’s impartiality since 2023, through our Impartiality Advisory Committee (IAC). The IAC was introduced because of bluesign’s aim to formalize the management of impartiality by gathering external input and advice. This was in place well before the EmpCo directive.

7. The scheme allows use of a corresponding sustainability label

Three marks sit within the scheme: bluepass Chemical Product, bluepass Article, and bluepass Consumer Product.

What this means for System Partner companies

Nothing changes. Existing certifications remain valid. Assessment and product registration continue as they are. There is nothing to submit, renew, or resubmit.

Product already in the market

If you have product on the market carrying a bluepass label, you can continue to sell it after 27 September, through to your next re-assessment. This avoids disrupting your certification cycles disproportionately, and follows bluesign’s discussion with the EU Commission on 1 September 2026.

Existing bluesign® PRODUCT and bluesign® APPROVED labels

These marks remain valid, and switching to bluepass is a labeling change rather than a certification one. There is no need to relabel, withdraw, or destroy bluesign® PRODUCT and bluesign® APPROVED label stock. Move to bluepass at your next label production cycle.

If you have a specific case you are unsure about, contact us and we will work through it with you.

Our own requirements, open to challenge

Two of the seven requirements are that a scheme’s requirements are publicly available, and set in consultation with relevant experts and stakeholders. Our revised bluesign Criteria and a new Scheme document publish for public consultation this month. Anyone can read them and tell us where we need to adjust.

A scheme that asks brands to substantiate their claims should be willing to open its own to scrutiny.

Webinar: 25 September

Chu Wong has helped lead our work on EmpCo. She is running a session covering the directive, how bluepass meets its requirements, and what happens to product already in the market.

Friday 25 September, 3:00 PM CEST.

Register here

Send questions in advance to info@bluesign.com.

A note on responsibility

Under EmpCo, responsibility for a compliant claim sits with the company placing the product on the EU market. bluesign provides guidance, recommendations, and the substantiation behind the bluepass mark. It does not replace independent legal advice.