EMPCo is Coming: Is Your On-Pack Logo Ready?

Much of the discussion around EMPCo has focused on claims such as “eco-friendly”, “sustainable” and “carbon neutral”. However, many manufacturers are using the legislation as an opportunity to review all the logos, symbols and trust marks displayed on their packaging.

If your products carry a vegetarian, vegan or plant-based logo, now is a good time to ask an important question:

What sits behind the mark you’re using?

What is EMPCo?

The Empowering Consumers for the Green Transition Directive (EMPCo) is new EU legislation designed to strengthen consumer protection and tackle misleading environmental claims.

The Directive introduces stricter rules around environmental claims and sustainability labels, including greater scrutiny of the schemes and verification processes that sit behind them.

Its objective is simple: consumers should be able to trust the claims and labels they see on products.

One area receiving particular attention is the use of sustainability labels and trust marks where consumers may not have clear information about what the label means or how it is verified.

While EMPCo is primarily focused on environmental and sustainability-related claims, many businesses are taking the opportunity to review their wider claims strategy and the third-party marks they rely on to communicate information to consumers.

What Will EMPCo Mean for Food and Drink Brands?

For food and drink manufacturers, EMPCo is prompting a broader review of packaging claims and consumer-facing communications.

Increasingly, the organisations asking questions are not consumers, but retailers, legal teams, regulatory affairs specialists and compliance departments.

Questions such as:

What does this third party logo actually mean?

Is there a clear set of criteria behind it?

How are products assessed?

Is there a transparent approval process?

Can we explain the basis on which approval was granted?

What evidence supports the claim being communicated?

These questions are not limited to environmental claims. Businesses increasingly want confidence that any logo displayed on-pack is supported by a credible and transparent process.

For brands selling across multiple markets, particularly into the EU, demonstrating that confidence can be just as important as consumer recognition.

The question is no longer simply whether consumers recognise a third party logo. Increasingly, businesses are asking whether they can confidently explain what it means, how it is awarded and what sits behind it.

Is It Safe to Put a Generic “V” on Your Packaging?

Many products use a simple “V” symbol or self-declared vegetarian or vegan statement.

These symbols can provide a useful indication to consumers, but they typically offer little information about:

• the criteria used;
• whether ingredients have been independently reviewed;
• who assessed the product;
• how decisions were made;
• what checks were carried out;
• how compliance is monitored over time.

This does not necessarily make generic symbols problematic. However, as scrutiny of consumer claims increases, many businesses are choosing to support their claims with independent assessment rather than relying solely on self-declaration.

A useful question to consider is:

If a retailer, compliance team or customer challenged your claim tomorrow, what evidence would you provide?

A recognised third party certification scheme can provide additional confidence for consumers, retailers and internal compliance teams alike.

Are Your Current vegetarian or vegan labels Robust Enough?

One of the most important questions organisations should be asking is:

What sits behind the third party logo?

Historically, many vegetarian and vegan approval marks have been regular Trade Marks. However, in legal terms a Trade Mark only functions as a designator the origin of a product, service or programme- i.e. it indicates where it comes from. It can be an effective way of building consumer recognition and trust, but a Trade Mark is not supposed to describe characteristics of the product. In terms of a third party vegetarian or vegan Trade Mark, they don’t actually prescribe how products are assessed, what criteria must be met, or what governance processes sit behind its use.

Certification schemes, by contrast, are typically built around defined standards and documented assessment processes. They are designed to provide assurance that products have been evaluated against specific criteria before approval is granted. Depending on the scheme, this may include formal application procedures, technical reviews, ongoing monitoring and governance controls.

In order to formally designate the characteristics of a product it is necessary to use a Certification Mark, which is a different legal right to a Trade Mark. Certification Marks are owned by independent testing or authenticating bodies, and are typically built around defined standards and documented assessment processes. They are designed to provide assurance that products have been evaluated against specific criteria before approval is granted. Depending on the scheme, this may include formal application procedures, technical reviews, ongoing monitoring and governance controls.

As a result, two logos may appear similar on-pack whilst operating very differently behind the scenes. If a logo is a Trade Mark it only indicates trade source. However, if a logo is a Certification Mark it indicates specific criteria of the product, which are supported by documented standards, assessment procedures and governance controls.

This distinction is becoming increasingly relevant as regulators and businesses place greater emphasis on transparency and substantiation. EMPCo introduces specific provisions relating to sustainability labels, including a preference for labels that are based on Certification Mark schemes or established by public authorities. While vegetarian and vegan marks are not environmental claims in themselves, the broader direction of travel is clear: organisations are increasingly expected to be able to explain what a label means, how it is awarded and what evidence sits behind it.

As businesses review their packaging and claims strategies, it is therefore worth understanding exactly how any third-party scheme operates and what level of assurance it provides.

Is Your Current packaging / branding Future-Ready?

Consider the following questions:

✔ Is my vegetarian or vegan label a Trade Mark or a Certification Mark?

✔ Are there published criteria?

✔ Is there a documented assessment process?

✔ Is there a clear decision-making framework?

✔ Are conflicts of interest managed?

✔ Is there an appeals process?

✔ Is there ongoing monitoring after approval?

✔ Could you confidently explain all of the above to a retailer, regulator, customer or legal team?

If the answer to any of these questions is “no” or “not sure”, it may be worth reviewing the level of assurance your current scheme provides.

Questions to Ask Your Scheme Provider

If you currently use a vegetarian, vegan or plant-based logo, one of the first questions to ask is:

Is this a Trade Mark, or a Certification Mark?

Understanding the answer can help you better assess the level of assurance and governance behind the symbol displayed on your packaging.

You may also wish to ask:

Is there a published standard or set of criteria?

How are products assessed?

Who makes approval decisions?

Is there a documented review process?

How are conflicts of interest managed?

Is there an appeals process?

How is ongoing compliance maintained?

What ongoing checks are carried out after approval is granted?

Increasingly, businesses are looking beyond logo recognition alone and seeking assurance that claims are supported by transparent and well-governed processes.

Why Robust Certification Matters

As expectations around consumer claims continue to evolve, many organisations are looking for ways to demonstrate greater transparency and consistency.

Certification Mark schemes can help reduce ambiguity by clearly defining what is being assessed and certified.

In the case of dietary certification, the focus remains on whether a product meets vegetarian, vegan or plant-based criteria, rather than making broader environmental claims.

Robust certification is not simply about meeting today’s expectations. It can also help businesses:

• support retailer conversations;
• answer legal and compliance queries;
• demonstrate how claims are substantiated;
• provide greater transparency to consumers;
• reduce uncertainty when packaging and claims are reviewed.

For manufacturers, this can provide greater confidence when communicating dietary suitability to consumers.

Why Choose Vegetarian Society Certification?

For more than 180 years, the Vegetarian Society has helped consumers make informed food choices.

As businesses ask more questions about the logos they display on-pack, the robustness of the scheme behind the mark becomes increasingly important.

That is why our Vegetarian Approved, Vegan Approved and Plant-Based Approved Certification Marks are built around clear criteria, documented assessment processes and governance controls designed to provide confidence for manufacturers, retailers and consumers alike.

Clear Standards

Products are assessed against defined criteria rather than broad marketing statements.

Evidence-Based Assessment

Applications are reviewed against documented requirements and ingredient information to ensure consistency and transparency.

Transparent Processes

Our Certification Marks are supported by documented procedures and governance controls designed to provide confidence for both businesses and consumers.

Trusted Consumer Recognition

The Vegetarian Society Approved logos have appeared on thousands of products and are widely recognised by consumers seeking vegetarian, vegan and plant-based options.

Confidence for Brands

Our Certification Marks provide manufacturers with a clear and credible way to communicate dietary suitability through independently assessed approval marks.

Now Is the Time to Review Your Packaging

EMPCo is encouraging many organisations to take a fresh look at the claims, logos and trust marks displayed on their products.

Whether you currently use a generic “V”, a self-declared claim or another third-party Trade Mark, now is a good opportunity to review the process and governance behind it.

The questions being asked about packaging claims and approval marks are becoming more sophisticated.

A simple question to ask is:

Can you confidently explain what sits behind your logo?

If not, it may be worth reviewing whether your current approach provides the level of assurance your business, customers and retail partners increasingly expect.

To learn more about Vegetarian Society certification and how our schemes can support your products, get in touch with our team.