The EmpCo Directive (Directive (EU) 2024/825) took effect in the European Union on Sunday September 29, 2026. In this post, our Verification Manager Fershad Irani, and Director of Policy Chris Adams, cover what the directive means in relation to our hosting provider verification process and Green Web Badge.
The short version
TLDR: We have just concluded a 2 year process to update the criteria we use for verifying hosting providers, to align with standards required by changes in the law related to the EU “EmpCo” directive. However if you are using the Green Web badge to say you are using “green hosting” or citing a result from our checking services to say the same, it may be contravening the directive, which carries its own risks.
If in doubt, we recommend removing the Green Web badge from your site until we publish the planned version with updated copy, and we share further guidance on how best to communicate about use of a hosting provider we have verified. We intend to publish this later in October, and by the end of November at the very latest.
The longer version
EU Directive 2024/825 “Empowering Consumers for the Green Transition” (referred to as EmpCo for the rest of this post), is an EU-wide directive aimed at preventing greenwashing, early obsolescence, and non-certified sustainability labelling practices. The directive, which went into effect on September 27th this year, aims to ensure that consumers looking to make sustainable purchasing decisions can do so on the basis of reliable, clear, evidence-backed claims from the companies that are selling to them. There are also provisions in the directive to support right-to-repair movements, which are key in the fight to reduce e-waste.
With its focus on green labelling schemes and evidence-based green claims, the EmpCo Directive has significant relevance to our work at the Green Web Foundation. In particular, our hosting provider verification process and the use of our Green Web Badge. A few concerned folks have already written to us about this, and while we do not view EmpCo as posing an immediate threat to our verification process, we do need to provide clearer guidance about how to use the badge, and make communications about using verified providers without falling afoul of the new law.
In this post, we’ll cover off what that means, and what hosting providers and Green Web Badge users can do in the meantime. If you’re looking for a detailed explainer on the directive itself, this website is one of the most accessible for understanding what the new law means for your own messaging : https://empcodirective.eu
Before continuing it is worth pointing out that we are not legal experts, and what we present here is based on our best understanding of the EmpCo Directive. It is not legal opinion or advice, and should not be viewed in that light.
EmpCo and Green Web Foundation provider verification
The EmpCo Directive applies to business-to-consumer (B2C) marketing, while our provider verification process represents a business-to-business scenario where one business (a hosting provider) is sharing information with another business (Green Web Foundation) to support claims they are making about using carbon-free energy to deliver their services. Viewed solely through this lens, it could be argued that the verification process is safe under EmpCo.
However, the verification process underpins a lot of other things that could potentially be construed as B2C marketing such as the Green Web Check, Hosting Directory, and Green Web Badge. It is also not unreasonable to see how it may be interpreted as a certification scheme itself. Therefore, we do believe there is work for us to do to ensure that our verification process is compliant with EmpCo.
Recent changes to our verification are a start
The Green Web Foundation hosting provider verification process has existed in some way, shape, or form since 2006. That’s over 20 years of helping shape how we define “green hosting” and tracking the transition of the internet away from fossil fuels.
On October 1, 2026, we implemented the biggest changes to our green hosting verification criteria since it began, after a review period that began with stakeholders in September 2024. The changes align our verification criteria with the most rigorous standards we could find in use – the Climate Group’s RE100 and 24 /7 Carbon-free Technical Criteria – and we require providers to share updated disclosures with us to support claims they are using carbon-free energy for their hosting infrastructure. This is in addition to our work with LINGO, another civil society organisation and CEN /CENELEC, the European Standards body, to develop a working definition of “Fossil-free” when applied to digital services”.
The changes also see carbon offsets no longer accepted as a means of making carbon-free energy claims, something that aligns with the direction of the EmpCo Directive. In June this year, we published a blog post summarising these changes, and you can see our updated verification criteria elsewhere on our website.
There’s more to do
While the changes to our criteria significantly tighten what we consider to be a “green claim” for the purposes of being listed in our Green Web Dataset, we still believe there is more we need to do to ensure our verification process meets the standards outlined by the EmpCo Directive.
In particular, while we don’t call our verification service a “certification scheme”, it’s not hard to find examples of people calling it this in their own communications, and we have not published guidance discouraging this, nor have we been actively and publicly policing against this usage.
Faced with this, we see two options:
- Go through the process to become a recognised certification scheme in the eyes of EmpCo, inline with how we see people using our badge and checks. This would entail us undergoing annual audit and monitoring by an independent third-party, becoming ISO 17065 accredited. As a Dutch Foundation, we would be registered with Raad voor Accreditatie (RvA) in the Netherlands.
- Require every single provider seeking verification to submit evidence of an independent third-party audit of their claims. We explain why this is less than ideal below.
Option 2 may work for larger providers, but feel that this approach would put undue strain on smaller providers who mean well but may not have the resources to undertake such compliance tasks themselves. We believe this would make it harder to have a diverse healthy ecosystem of small digital providers as well as larger ones.
Our focus is on Option 1, the certification scheme route – we would have our verification process itself independently audited and monitored to ensure compliance and registered with the RvA. This would mean the scheme would be recognised within the Netherlands and Europe, but also mean it would recognised globally, because the RvA is a member of the Global Accreditation Cooperation Incorporated (Global ACI). This would provide a degree of certainty about use that currently does not exist.
However, this likely would incur significant costs that exceed the donations we currently receive for running our verification scheme. With this in mind, we are currently looking into how best to fund this work, and will share more later in Q4.
EmpCo and the Green Web Badge
The work covered above to tighten up and certify our verification process will go a long way to ensuring other parts of the Green Web ecosystem also meet the compliance requirements outlined under the EmpCo Directive. However, we have received a few questions from folks about our Green Web Badge in particular and so we’d like to take the chance to address those here.
Q: Do the Green Web Badges in their current form comply with the EmpCo Directive?
A: While we can’t give a definitive legal answer, our position is that “no, they likely do not”. The words “green hosting”, are the issue, because the term “green” is unqualified. We plan to update the wording of the badges in October/November – moving away from “green hosting” and towards more specific wording. This is a small step in the process of moving towards compliance, which would be coupled with the overall verification process evaluation mentioned above.
Q: Is the Green Web Badge a “labelling scheme”?
A: It can be construed in this way, however, it is important to be clear about what the Green Web Badge actually represents when it is displayed on a website.
In the overwhelming number of cases where it is used on a website, the Green Web Badge does not represent an endorsement or certification of the products/services being sold by the company using the badge. Nor is it an endorsement by the Green Web Foundation of the organisation owning the domain on which is it shown.
The Green Web Badge only shows the details of the hosting provider that is used for a website, and whether that provider is listed in our Green Web Dataset. This means that the provider has completed the verification process and shown reasonable evidence to allow us to determine they are using fossil-free energy to power their hosting infrastructure.
The only exception to this would be when a hosting provider themselves shows a Green Web Badge on their own website as proof that they have in fact completed the our provider verification process. In these cases, we would strongly advise that providers remove the badge and replace it with “Our infrastructure is verified to use fossil-free energy, as assessed under the Green Web Foundation’s criteria“.
I am a website owner using the Green Web Badge, what should I do?
If you have any doubts or hesitation about the badge, then we would recommend removing it from your site for now until the work mentioned in above is completed. You can instead use wording like: “This domain is hosted with a provider verified to be in the Green Web Foundation’s Green Web Dataset. They have disclosed information backing claims to use carbon-free energy to deliver their hosting services.”
You can stay up-to-date with our progress on the work mentioned in this blog post, and for further updates on the EU EmpCo Directive as it relates to not only our work but the digital sustainability sector at large. The best places to do so are by following us on LinkedIn or signing up to our monthly Newsletter.
We are currently investigating the full costs and implications of a transition to a certification scheme as described, and fundraising to make this possible. If you find value in our work, and you’re interested in contributing to the funding of this work, we’d love to hear from you – please drop us a line via our contact form.
