1. Has the EmpCo Directive been implemented into national law?
    1. Which national legislative act(s) implement the EmpCo Directive?
    2. Does the national implementation provide for a literal (1:1) transposition, measures exceeding the minimum harmonisation requirements, or specific deviations? 
    3. Has a draft implementing act already been published?
    4. What is the expected timeline for transposition of the Directive?
    5. Are any provisions envisaged exceeding the minimum harmonisation requirements, or specific deviations? Please specify.
  2. Have official guidelines, FAQs or interpretative guidance been issued by competent authorities or consumer protection bodies regarding the application of the EmpCo Directive?
  3. Are there any national or regional EN ISO 14024 type I ecolabelling schemes that substantiate a generic environmental claim as they demonstrate “recognised excellent environmental performance”?
  4. Which sanctions and enforcement mechanisms are available or envisaged (e.g. administrative fines, prohibition orders, injunctions, market bans, civil enforcement actions)?
  5. Which authorities or institutions are competent for enforcement and supervision?
  6. Is there already specific case law on environmental claims and/or sustainability labels? 

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1. Has the EmpCo Directive been implemented into national law?

Yes - the provisions amending Directive 2005/29/EC have been implemented, however those amending Directive 2011/83/EU have not.

1.1 Which national legislative act(s) implement the EmpCo Directive?

Amendments to Directive 2005/29/EC have been transposed via Act XCIV of 2025 ("Amending Act") and implemented into Act XLVII of 2008 on the Prohibition of Unfair Commercial Practices against Consumers ("UCP Act") effective as of 27 September 2026.

The Amending Act is available at: https://njt.hu/jogszabaly/2025-94-00-00.0#CI, while the current text of the UCP Act is available at: https://njt.hu/jogszabaly/2008-47-00-00 (in Hungarian).

1.2 Does the national implementation provide for a literal (1:1) transposition, measures exceeding the minimum harmonisation requirements, or specific deviations? 

The EmpCo Directive's provisions were essentially transposed literally (1:1) into the UCP Act.

1.3 Has a draft implementing act already been published?

No (for the provisions amending Directive 2011/83/EU).

1.4 What is the expected timeline for transposition of the Directive?

Unknown (for the provisions amending Directive 2011/83/EU).

1.5 Are any provisions envisaged exceeding the minimum harmonisation requirements, or specific deviations? Please specify.

Unknown (for the provisions amending Directive 2011/83/EU).

2. Have official guidelines, FAQs or interpretative guidance been issued by competent authorities or consumer protection bodies regarding the application of the EmpCo Directive?

No.

However, in 2020, the Hungarian Competition Authority ("HCA") published its Green Marketing Guidance (on the criteria businesses should consider when developing their sustainability-related commercial communications) and in 2024, it published a study summarizing the results of its market analysis into green claims. Although these materials predate the EmpCo Directive, they may still be relevant as to the HCA's approach to green communication in general.

3. Are there any national or regional EN ISO 14024 type I ecolabelling schemes that substantiate a generic environmental claim as they demonstrate “recognised excellent environmental performance”?

Yes, the “Környezetbarát Termék” (Hungarian National Ecolabel) is an ecolabelling scheme meeting the requirements of the EN ISO 14024 standard. It is granted through an application process based on predefined criteria systems.

Professional management of the ecolabel certification system is provided by the ministry responsible for environmental protection (currently the Ministry for Energy). The system is operated by the Ecolabel Certification Office within the Environmental Directorate of HungaroMet Nonprofit Zrt. Decisions regarding the development and modification of national requirement systems are made by the Evaluation and Qualifying Committee, which consists of independent experts.

Ecolabels may be awarded to products and services that have a significant environmental impact and where the potential for reducing environmental burden is outstanding. These primarily include goods used extensively and in large quantities—such as detergents, paper products, textiles, furniture, building materials, and accommodation services.

4. Which sanctions and enforcement mechanisms are available or envisaged (e.g. administrative fines, prohibition orders, injunctions, market bans, civil enforcement actions)?

Normal sanctions for misleading commercial practices, depending on the competent authority.

The government office acting as consumer protection authority may, for example: 

  • Impose administrative fines up to 5% of the company’s annual net turnover or HUF 3 or 5 billion (precise fine ranges vary depending on the type of infringement and the size of the company);
  • Order the cessation of the illegal practice 
  • Order remediation with set deadlines
  • Restrict or ban sales
  • Order temporary business closure (for up to 30 days/until safety is ensured if the infringement causes significant financial loss/safety threat to a wide range of consumers).

The HCA may, for example:

  • Impose administrative fines up to 13% of the company’s annual net turnover (currently, the fine cap is increased to 15% under the applicable state of danger regime);
  • Order the cessation of the illegal practice;
  • Issue a formal warning (for first-time offender SMEs) instead of a fine, provided they implement an internal compliance program;
  • Enforce voluntary commitments made by the company.

5. Which authorities or institutions are competent for enforcement and supervision?

The UCP Act is enforced by consumer protection authorities. Generally, the competent consumer protection authorities are the territorial government offices, however, if the conduct is capable of affecting competition, the HCA has competence (i.e., primarily in case of online/country-wide campaigns).

6. Is there already specific case law on environmental claims and/or sustainability labels? 

In case No. VJ/34/2022., the HCA found that CUP Revolution Ltd. misled consumers with environmental claims regarding its reusable cup system (specifically regarding reusability, waste reduction, and sustainability). While no fine was issued, the HCA issued a formal warning and ordered the company to implement a compliance program, audit all current marketing materials to align environmental claims with the principles of this decision, and improve transparency by ensuring consumers receive clear, proactive information about the system before and during purchase, without placing an undue burden on the consumer to seek out these details. The decision is available at: https://gvh.hu/preview/pfile/file?path=/dontesek/versenyhivatali_dontesek/versenyhivatali_dontesek/dontesek-2022/Vj034_2022_m_v.pdf1&inline=true (in Hungarian).

Furthermore, multiple HCA investigations were launched in August 2024 regarding claims on the labels of mineral water and soft drink bottles - and in other commercial communications - concerning the environmental impact of the products, which are likely to deceive consumers. The claims mostly concern the "recycled" and "recyclable" nature of PET bottles.

One such investigations (case No. VJ/33/2024.) was closed on 20 March 2026 with commitments. In that case, the HCA considered that the challenged communications could have created the impression that the bottle as a whole - including the cap and the label - was made from recycled material, whereas only the body of the PET bottle itself contained recycled content. The commitments include 

  1. a comprehensive compliance initiative
    1. development of internal processes governing commercial communications, 
    2. the appointment of a compliance expert, 
    3. adoption of a detailed internal compliance policy for future commercial communications, including specific measures relating to environmental claims - as well as 
  2. implementing educational measures/consumer awareness campaign, including the preparation of materials addressing the environmental impacts of bottled products and the importance of bottle return systems. The decision is available at: https://www.gvh.hu/pfile/file?path=/dontesek/versenyhivatali_dontesek/versenyhivatali_dontesek/dontesek-2024/Vj033_2024_m.pdf1&inline=true (in Hungarian).