1. Has the EmpCo Directive been implemented into national law?
    1. Has a draft implementing act already been published?
    2. What is the expected timeline for transposition of the Directive?
    3. 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? 

jurisdiction

Poland
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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 - together with publication of draft, the intended date was set for the first quarter of 2026. However, as of April 2026 the draft is still at the early stage of the government process, and no new planned deadline was set.

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”?

Yes, Znak Ekologiczny EKO is a Polish Type I environmental ecolabelling scheme compliant with ISO 14024. The label is awarded through a voluntary certification programme managed by the Polish Centre for Testing and Certification (PCBC).

The Znak Ekologiczny EKO label confirms that a product meets strict environmental and health protection requirements, including criteria related to environmental impact, protection of human health, and efficient use of natural resources throughout the product life cycle.

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

Available enforcement and sanctions will not change in comparison to current general consumer protection rules used to enforce greenwashing (see Q6):

  1. Administrative fines – the President of UOKiK (Polish Competition and Consumer Protection Authority) may impose fines (i) on company of up to 10% of annual turnover and (ii) on managers up to approx. EUR 470,000.
  2. Civil liability – affected consumers (and consumer organisations) may demand in particular: cessation of the infringing practice, removal of its effects, compensation for damages, publication of a statement or payment of an appropriate sum to a social cause.

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

  1. President of the Office of Competition and Consumer Protection (UOKiK)
  2. Civil courts

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

No UOKiK decisions have been issued yet, but multiple proceedings have been launched based on general consumer protection laws (in particular unfair commercial practices). Charges were pressed against major companies from the e-commerce, logistics/transport, textile and FMCG sectors. Examples of the questioned slogans include: “Logistics on a green course – we care about the environment”, “environmentally friendly shipments” and “Our goal: Zero CO2 emissions by 2050”. UOKiK is also investigating other companies from the textile and cosmetic sectors.

In addition to the official UOKiK proceedings, in Poland green claims are also under review of The Advertising Council (a non-governmental, non-profit association to which various big market players belong), which has created a self-regulation Code of Advertising. The Council has in the past issued resolutions related to green claims, e.g. use of the terms "eco-coal" or "carbon-neutral".