I think I got it. The effective action is a functional of $\phi_c$, $\Gamma[\phi_c]$. The classical field $\overline{\phi}$, i.e. the one that reduces to $v$ in the zero current limit, is only the solution to the EoM,
$\frac{\delta\Gamma}{\delta \phi_c}\bigg\rvert_{\phi_0}=-J(x)$. Now we're working with fixed current (i.e. $\phi_0$ is a function of $J$), so sending it to zero we get the desired result. $\phi_c$ is just an arbitrary variable