When I talk with retail and logistics leaders this year, the same question keeps coming up: can their carbon numbers hold up under scrutiny?
Two EU measures coming into force in 2026 are pushing that question into the open. The Packaging and Packaging Waste Regulation (PPWR) applies from August. Directive 2024/825, better known as the Empowering Consumers Directive or “EmpCo,” applies from late September. They cover different ground, but they share an underlying demand: claims about environmental impact need to be specific, evidence-led, and easy for a regulator to verify.
At nShift, we see this playing out in the questions sustainability teams are starting to ask their carriers and their software vendors. The bar for what counts as a credible number is moving up. We laid out the headline implications in our recent announcement; this piece goes deeper into what “verifiable” will actually require.
What is actually changing in 2026
From August 2026, PPWR introduces measurable targets for ecommerce packaging, including delivery-packaging reuse rates and limits on void space inside parcels. From late September 2026, the Empowering Consumers Directive updates EU consumer-protection law to require that environmental claims, including carbon-related ones, are substantiated. Generic averages and uncited “carbon neutral” statements stop being safe defaults.
Both pieces of regulation point to the same operational discipline. If you tell a shopper at checkout that a shipment is low carbon, you need the data behind the phrase. If you report packaging reuse rates to a national authority, you need a method that someone outside your business could follow and reproduce.
Why generic carbon averages will not survive scrutiny
The EmpCo Directive did not appear in a vacuum. In a November 2020 sweep across 27 countries, the European Commission and national consumer protection authorities examined 344 environmental claims on EU traders’ websites. They found that 53.3% of those claims were vague, misleading, or unfounded, and 40% had no supporting evidence at all. That evidence sits directly behind the EmpCo Directive that takes effect in September.
53.3%
of EU green claims found vague, misleading, or unfounded
2020 European Commission sweep across 27 countries
20 airlines
investigated by the EU's CPC Network for misleading green claims
April 2024, the first coordinated EU sweep targeting a single sector
Sept 2026
Empowering Consumers Directive applies across the EU
All environmental claims to consumers must be substantiated
Enforcement has tightened since 2020:
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In March 2022, Sweden’s advertising regulator ruled Budbee’s “100% fossilfritt” parcel locker claim misleading because the wording covered only transport fuel but could reasonably be read as covering the whole operation.
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The following year, Sweden’s Patent and Market Court told Arla its “net-zero” milk claim was misleading because consumers could not be expected to understand the long-horizon offsetting behind it.
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In April 2024, the EU’s Consumer Protection Cooperation network opened a coordinated investigation of 20 European airlines over comparable concerns.
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Across the Channel, the UK’s Digital Markets, Competition and Consumers Act has given the CMA direct fining power of up to 10% of global turnover for misleading environmental claims since April 2025.
For ecommerce, the practical implication is: industry-average carbon factors applied to a shipment lane no longer pass as “verifiable” under the new standard. What stands up to scrutiny is a calculation a regulator could reproduce, given the same inputs and a published methodology. Anything less leaves the brand carrying the legal and reputational risk.
This is also why the Empowering Consumers Directive was paired with a tighter regime for environmental labels. A label that a company places on its own checkout, packaging, or marketing now has to meet a clear evidentiary standard. The shortcut of borrowing language from a supplier’s marketing deck closes off in September.
What ISO 14083 actually changes about emissions reporting
For logistics and ecommerce teams, the methodology question usually lands in one place: ISO 14083, the international standard published in 2023 for calculating and reporting transport-chain greenhouse gas emissions. The GLEC Framework, maintained by the Smart Freight Centre, is the operational implementation that most carriers and shippers in Europe are working toward.
Data hierarchy is where ISO 14083 changes things most. The standard sets a clear preference for primary data from carriers, accepts modeled data where primary data is unavailable, and treats industry default values as the last resort. The closer a retailer’s reporting sits to primary data, the stronger the claim.
Scope is also wider than the truck. ISO 14083 covers well-to-wheel emissions across the whole transport chain, including upstream fuel and energy production. A claim built on tank-to-wheel data alone will read as incomplete under scrutiny.
Consistency across carriers is where the operational gain shows up. A retailer with twelve carriers running on twelve different methodologies has twelve sets of numbers that cannot be added together cleanly. A standardized calculation across the whole network is what turns a reporting burden into a usable dataset, and an auditable one.
We built nShift Emissions Tracker with that consolidation in mind. In March 2026, the Smart Freight Centre certified the Emissions Tracker methodology against ISO 14083 and the GLEC Framework, which gives our customers an independent line of evidence to point to when an auditor, a customer, or a journalist asks for it.
A readiness check for ecommerce teams
If you are reviewing your own position before August, these five questions are worth asking inside the team.
- Can you produce a carbon figure for any individual shipment in the last twelve months, on demand, with the methodology documented?
- Are the calculations consistent across every carrier you use, including regional and specialist providers?
- If a consumer protection authority asked for the evidence behind a “low carbon delivery” claim at checkout, what would you send?
- Does your packaging data flow into your reporting system the same way your emissions data does, or are they two different spreadsheets?
- Who in the business owns the answer when a customer or auditor pushes back on a number?
Those questions are deliberately operational. Compliance teams are best placed to interpret the regulation. The hard work in 2026 will be done by the people who actually run delivery and returns.
The packaging side: where PPWR shifts returns operations
PPWR’s reuse targets and void-space limits sit on a different part of the operational map. They reach into how parcels are assembled, which carrier services are chosen, and how returns flow back so packaging can be recovered.
Most ecommerce teams I speak with are still mapping what those targets will mean for their carrier mix and their reverse logistics. The honest read is that 2030 is when the reuse percentages bite, and there is real preparatory work in the meantime. Returns flows that recover packaging cleanly, carrier services that support reusable formats, and reporting that lets a regulator see the loop closing on its own merits.
A modern returns operation helps on the data side, even before the packaging redesign work is finished. If you cannot see what is coming back, you cannot improve what you send out.
What I would do this quarter
If I were running ecommerce sustainability for a European retailer right now, two things would be on my desk.
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An honest review of every environmental claim my brand makes on its website, at checkout, on packaging, and in marketing. If the evidence behind a claim is thinner than the claim itself, tightening the language before September is safer than waiting for a regulator to point it out.
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A one-page view of how emissions data moves from carrier to reporting system across the business. If that flow has manual steps, format conversions, or single-source dependencies, those are the first cracks that will show under audit.
Both are operational questions that also get easier once the platform underneath is doing the consolidation work for you.
The retailers in the strongest position at the end of 2026 will be the ones whose carbon numbers hold up when an auditor, a journalist, or a customer asks to see the calculation. That is a smaller club than the one currently making green claims on checkout pages, and it is the one worth being in.
If you want to see how Emissions Tracker handles the methodology side of the work, our team is happy to walk through it. Talk to us about a demo.
About the author
Fredrik Lindhagen
Product Manager, nShift
Fredrik has 15+ years of experience within the shipping industry. At nShift his responsibility is in developing our Transport Management Solution as well as evolving the Emissions Dashboard allowing customers to keep track of and reduce their CO2 emissions.