Implementation tracker for the EmpCo Directive - Luxembourg
- Has the EmpCo Directive been implemented into national law?
- Have official guidelines, FAQs or interpretative guidance been issued by competent authorities or consumer protection bodies regarding the application of the EmpCo Directive?
- 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”?
- Which sanctions and enforcement mechanisms are available or envisaged (e.g. administrative fines, prohibition orders, injunctions, market bans, civil enforcement actions)?
- Which authorities or institutions are competent for enforcement and supervision?
- Is there already specific case law on environmental claims and/or sustainability labels?
jurisdiction
1. Has the EmpCo Directive been implemented into national law?
No.
1.1 Has a draft implementing act already been published?
Yes.
1.2 What is the expected timeline for transposition of the Directive?
Unknown; the draft bill was filed on 29.10.25, the opinion of the Counsel of State was delivered on 10.03.26 and a further report of the Agricultural Commission is expected on 26.03.26; therefore, it seems unlikely that the 27.03.26 deadline will be met.
1.3 Are any provisions envisaged exceeding the minimum harmonisation requirements, or specific deviations? Please specify.
No.
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.
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”?
No, Luxembourg does not operate its own national EN ISO 14024 Type I ecolabelling scheme; however, products and services marketed in Luxembourg may rely on the EU Ecolabel.
4. Which sanctions and enforcement mechanisms are available or envisaged (e.g. administrative fines, prohibition orders, injunctions, market bans, civil enforcement actions)?
The draft law transposing Directive (EU) 2024/825 operates by amending the Luxembourg Consumer Code (Code de la consommation); the existing sanctions and enforcement mechanisms under the Consumer Code shall apply to violations relating to environmental claims.
5. Which authorities or institutions are competent for enforcement and supervision?
Ministry of Consumer Protection (Direction de la protection des consommateurs) for supervision and in case of administrative sanctions, the Luxembourg courts competent for commercial matters.
6. Is there already specific case law on environmental claims and/or sustainability labels?
Currently, there is no established body of Luxembourg case law on environmental claims and/or sustainability labels relating to consumers. However, the CSSF (Commission de Surveillance du Secteur Financier), the Luxembourg financial regulator, has issued a regulatory sanction with respect to a financial product offered to retail investors due to deficiencies in sustainability-related disclosures under SFDR.
