The EmpCo Directive: what has to be on your product pages from 27 September 2026

Six weeks. That's roughly how much time you have left, as you read this, until 27 September 2026. That's the day the rules from the EmpCo Directive (EU) 2024/825 – "Empowering Consumers for the Green Transition" – become applicable across the EU. The place they hit hardest is the exact spot where the buying decision happens: your product page.

In a bit more detail: the EmpCo Directive changes European consumer law at two ends. It demands more pre-contractual information – before someone clicks "buy", they should know how repairable a product is, whether spare parts exist, and what warranty and guarantee rights come with it. And it bans a whole range of marketing claims that are still standard practice today.

This article walks through what belongs on the product page, where the legal traps are, what the EU energy label for smartphones and tablets has to do with it, what applies on top in France – and how to implement all of it in a Shopware store with 800 SKUs without touching 800 pages by hand.

One thing upfront: we're software engineers, not lawyers. What follows is how we read the rules from day-to-day project work – it is not legal advice. National implementations can differ from this summary; for a binding assessment of your case, talk to a law firm specialising in competition and IT law.

What applies from 27 September 2026 – the short answer

EmpCo isn't a standalone regulation. It amends two existing directives: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). For you that boils down to two sets of obligations:

1. Pre-contractual information duties. Details about durability, repairability, spare part availability and guarantees have to sit where the customer decides – on the product page, not buried in your terms and conditions.
2. A ban on misleading environmental claims. Blanket statements like "environmentally friendly" or "climate neutral" without solid evidence, self-made sustainability labels without independent certification, and advertising what the law already requires anyway – all off limits.

The timeline behind it: member states had to transpose the directive into national law by 27 March 2026; the new rules apply from 27 September 2026. In Germany, the implementation runs mainly through amendments to the Act Against Unfair Competition (UWG) plus supplementary consumer protection provisions. Still check the actual status for each of your target markets – the national implementations aren't word-for-word identical.

EmpCo or Right to Repair? Two things that constantly get mixed up

A second set of obligations lands on retailers in the same window, and the two get thrown into one pot all the time:

In short: EmpCo is pre-purchase, Right to Repair is post-purchase. How the second part works – the choice notice, the one-off twelve-month extension of the statutory warranty after a repair, and what that means for your service process – we wrote up separately: Right to repair in your online store. Doing only one of the two means you're halfway there.

What actually belongs on the product page

The directive doesn't prescribe a layout. It says the consumer has to get the information clearly and in good time. In practice that means a dedicated, visible info block on the product detail page. These are the building blocks that belong in it, where they apply to your product:

• A repairability score plus its scale and source. "7" on its own says nothing. "7 out of 10, source: manufacturer" is a statement. The reference matters – an 8 on a ten-point scale is something entirely different from an 8 on a five-point scale.
• Spare part availability. Are there spare parts, for how long, and through which channel? An honest "no spare parts available" is a perfectly valid and useful piece of information too.
• A link to the manufacturer's repair service. One click through to the repair page saves you support tickets later.
• A note about the statutory warranty. Factually worded, not as a marketing promise (more on that in a second).
• A commercial guarantee, if there is one – with duration and scope, clearly separated from the statutory warranty.
• A label image, where one exists – for example the repairability part of the EU energy label.

One point that gets lost in implementation regularly: what you haven't maintained, you can't claim. A block that renders "spare parts available for 7 years" on every product because it's hard-coded in the template isn't compliance – it's misleading by design. So the right technical rule is: elements only appear where data actually exists.

Anti-greenwashing: what you can't write any more

The second half of the directive is the one that gets German stores their first letter, in our experience. Three patterns are critical:

1. Vague environmental claims without proof. "Environmentally friendly", "green", "sustainable", "climate neutral" – if you claim it, you have to be able to back it up. Without recognised evidence, the claim isn't allowed. That includes harmless-looking phrases buried in your product copy, not just big campaign slogans.

2. Your own labels without independent certification. The homemade "Eco Choice" icon in your sidebar is exactly what the directive is aimed at.

3. Advertising what the law already grants. This is the subtlest and most expensive mistake. Presenting the statutory warranty as a special service promise ("Get 2 years of warranty with us – exclusively!") means advertising an obligation you have anyway. Claims like that have always attracted warning letters, and the new legal framework sharpens the focus on them.

That's why our recommendation for every notice you add is: inform, don't advertise. "The statutory warranty of 24 months applies. After a repair, the period may be extended by 12 months." is information. "We're giving you 2 years of peace of mind!" is a liability.

The same goes for badges pointing at statutory manufacturer duties. In our plugin such a badge is deliberately off by default – switching it on should be a conscious decision, not something you slide into through a preset.

Special case: smartphones and tablets and the EU energy label

If you sell smartphones or tablets, you've had an extra, very concrete obligation on your plate for over a year. Since 20 June 2025, delegated Regulation (EU) 2023/1669 applies: these devices carry an EU energy label that shows, alongside energy efficiency and battery life, a repairability class from A to E. The classification factors in things like the number of disassembly steps, the tools required, spare part availability, and how long software updates and repair information are supplied.

For online retail that means the label has to be shown near the price and linked to the corresponding entry in the EPREL database. This isn't a recommendation or a nice-to-have – it's regulation, and it's already in force.

In practice the two frameworks complement each other nicely: for smartphones and tablets you already have an official, verifiable value in the A–E repairability class. You can feed it straight into the info block EmpCo asks for (score "A", scale "A–E", source "EU energy label") and put the label image right next to it. Whether and in what form the obligation applies to your specific range is something to check case by case.

France: indice de réparabilité and indice de durabilité

If you sell into France, there's a third layer. France has its own national labelling requirement for certain product groups: the indice de réparabilité (repairability index), which for some groups is being replaced by the broader indice de durabilité (durability index). It comes with a legally prescribed pictogram with a fixed design.

Important: this labelling is relevant for the French market only and differs in format from the EU repairability score. It neither replaces the EmpCo information nor is replaced by it. If France is one of your markets, check separately whether and how you have to add the index and its pictogram – ideally per sales channel, so German customers don't end up looking at the French pictogram and vice versa.

Why manual work doesn't scale across hundreds of product pages

In our projects we see the same pattern every time. The intent is there, the failure starts with the mechanics.

A store with 800 SKUs would need to do this 800 times: research the repairability score, note the scale and source, phrase the spare part information, find the manufacturer link, add the warranty note. Typing that into the product description creates four new problems: the text isn't structured (so it isn't filterable, analysable or properly translatable), it can't be corrected centrally, it goes live immediately instead of on the cut-off date – and half of it disappears with the next catalogue import.

On top of that, three requirements a text-snippet approach simply can't cover:

• Cut-off date logic. You want to maintain the data now but display it from 27 September. And you want to be able to shift that date if implementation in one of your markets differs.
• Per-channel differentiation. Different markets, different obligations, different wording.
• Verifiability. Where does each value come from? Without a documented source, a mandatory disclosure quickly turns into an unsupported claim – exactly what the directive is trying to prevent.

Our answer: our Shopware plugin "Right to Repair & EmpCo"

That's exactly the problem we built a Shopware plugin for: Right to Repair & EmpCo: Claims and Repairability. It covers both sets of obligations – the complaints workflow for Right to Repair and the product page information for EmpCo. This article is about the second part.

On the product page you get a "Repair & warranty" block containing the elements you have data for: repairability score with scale and source, an optional label image next to it, spare part availability, a link to the manufacturer's repair page, the commercial guarantee, and a factual warranty note.

Four details that make the difference day to day:

• Nothing shows before the cut-off date. The EmpCo date is preset to 27 September 2026 and can be changed per sales channel. So you can maintain data calmly today without anything changing in the storefront – and still be complete on the day.
• Nothing shows without data. Every element only renders if something is actually stored on the product. No placeholders, no blanket statements, no claims you can't back up.
• Everything is configurable per sales channel. Cut-off date, visible elements, wording – separately for each channel. The wording lives in text snippets and can be adjusted per language without opening a single product.
• The Annex II badge is deliberately off by default. See above: advertising a statutory obligation can get you a warning letter. The badge is an option, not a preset.

The part that saves the 800-SKU store is the bulk CSV import. You download a template with the correct header row, fill it in your spreadsheet app – product number plus repairability score, scale, source, spare part details, manufacturer repair URL, guarantee information, Annex II product group – and import it. It works in reverse too: export what's already there, edit it in Excel, import it back. That round trip is the fastest way to get a large catalogue clean.

So you don't retype the same thing on every product, there are also manufacturer defaults: spare part availability, manufacturer repair URL and commercial guarantee can be stored once per manufacturer and kick in wherever the product itself has nothing. A value on the product always wins. Deliberately excluded: repairability score, scale and source. Those are model-specific, and a blanket manufacturer value would be precisely the unsupported claim you're trying to avoid.

What the plugin explicitly does not do: check your data. It displays what you store. Accuracy and evidence stay your job – there's no software for that, only clean data.

The plugin is coming to the Shopware Store soon. If you want to be ready before 27 September: get in touch and we'll give you early access and look at your store together. How we approach Shopware plugins in general – from the idea to the store release – is on our services page.

Checklist: what to have done by 27 September

1. Review your range. Which product groups even have repairability scores, spare part commitments or manufacturer guarantees? Start with the categories that make the revenue.
2. Request manufacturer data. Repairability scores, spare part supply, repair URLs – that comes from the manufacturer or supplier. This request is the longest lead time in the whole project, so send it first.
3. Document your sources. Every value needs a source you can show if asked: manufacturer, EU energy label, the French repairability index, or your own assessment.
4. De-green your existing copy. Vague environmental claims, homemade labels and advertising of statutory rights: out (see the tip above).
5. Word the warranty note factually – as information, not as a promise.
6. Check the smartphone/tablet case. Energy label near the price, EPREL link, repairability class A–E.
7. Check France separately, if you sell there.
8. Switch it on technically. Import the data, set the cut-off date, preview it in a test channel – not on 26 September.
9. Get legal sign-off. The published wording and the cut-off dates you activate should pass a lawyer's desk once.

Wrapping up

The EmpCo Directive isn't a paper tiger or a distant future topic. The date is fixed, national implementation is under way, and the painful part isn't the information itself – it's the volume. Nobody updates 800 product pages by hand on 26 September.

The order that matters: get the data (ask manufacturers, document sources), clean up your claims (greenwashing and statutory-rights advertising out) and render it structurally (product data instead of body copy, cut-off logic instead of a last-minute scramble). All three are doable in six weeks – just not in six days.

By the way: if you're working on your product pages anyway, it's worth a look at the AI content labelling obligation for online stores – it hits the same templates and has applied since August.

Not sure how many of your products are actually affected – or whether your product pages already meet the new requirements? Then let's take a look together in a free initial consultation. We'll do an honest check of your store, tell you where the real gaps are, and show you the plugin live. No obligation, no sales pressure – and afterwards you'll know exactly where you stand.