EU's New Anti-Greenwashing Rules Take Effect Under ECGT Directive

The European Commission has published a Questions and Answers document clarifying how its Empowering Consumers for the Green Transition Directive, or ECGT Directive, applies now that the rules took effect on 27 September 2026. The Directive amends two existing consumer protection laws, the Unfair Commercial Practices Directive and the Consumer Rights Directive, to crack down on vague environmental claims, unverified sustainability labels and misleading durability information aimed at consumers across the EU. Rather than creating new environmental standards, the Directive works by tightening what businesses are legally allowed to say to shoppers about a product's environmental or social characteristics, shifting the burden onto traders to prove claims rather than leaving consumers to interpret them.

 

Generic Environmental Claims Are Banned Without Proof of Top-Tier Performance

 

Terms like "eco-friendly," "green," "climate friendly" or "biodegradable" now fall under a specific legal category called a generic environmental claim, defined as any such wording that isn't backed by a clear specification displayed on the same packaging or advertisement. Under the Directive, making this kind of unqualified claim is now prohibited outright unless the trader can demonstrate what the Commission calls recognised excellent environmental performance, verified through compliance with the EU Ecolabel, a national ISO 14024 Type I ecolabelling scheme such as the Nordic Swan or Blue Angel, or top performance under another applicable EU law such as the Energy Labelling Regulation.

The rule extends beyond text into packaging design itself: the Commission's guidance warns that imagery such as green leaves or water drops, when combined with written claims or logos, can be read by consumers as implicit environmental claims subject to the same requirements. A claim like "climate-friendly packaging" without further specification is treated as generic and banned, while a specific claim such as "100% of energy used to produce this packaging comes from renewable sources" is permitted because it can be independently verified.

 

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Carbon Neutrality Claims Can No Longer Rely on Offsetting Alone

 

Perhaps the most consequential change targets carbon neutrality marketing. Claims such as "carbon neutral," "climate net zero" or "CO2 neutral certified" are now prohibited outright when they rely on offsetting greenhouse gas emissions outside a product's own value chain, a practice the Commission says previously let companies imply a product had no environmental impact when the impact had merely been compensated elsewhere. A classic example cited in the guidance is an airline claiming a flight is climate neutral because it funds a reforestation project, a claim that no longer qualifies regardless of how the offset itself is verified.

The prohibition does not extend to claims based on a product's own actual lifecycle emissions, meaning companies can still market a genuine reduction in a product's carbon footprint if backed by lifecycle assessment data, nor does it stop companies from advertising investments in carbon credit projects as long as the marketing does not imply the product itself is neutral or impact-free. Claims about future environmental performance, including transition pledges to net zero, remain allowed only when backed by a detailed, resourced implementation plan verified regularly by an independent third-party expert whose findings are made public.

 

Sustainability Labels Must Be Tied to a Certification Scheme

 

Voluntary trust marks and quality marks referencing environmental or social characteristics, what the Directive calls sustainability labels, are now banned unless they are either established by an EU public authority or based on a certification scheme that meets specific transparency conditions. Those conditions require independent third-party verification, publicly available scheme requirements, monitoring against recognised international or EU standards, and open, non-discriminatory access for any trader willing to comply. Labels established by public authorities outside the EU do not qualify for this exemption, meaning third-country government sustainability labels are prohibited on the EU market unless they also satisfy the certification scheme criteria.

Any sustainability label already on the market when the rules took effect on 27 September 2026 had to meet these requirements immediately, since the Directive provides no transition period for existing labels. Traders using non-compliant labels must either bring their certification arrangements into line with the new criteria or remove the labels from their products and marketing altogether.

 

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Reparability Scores and Durability Information Now Required at Point of Sale

 

Alongside the environmental claims crackdown, the Consumer Rights Directive amendments introduce mandatory reparability scoring for products where the EU has set harmonised requirements, a system already in force for smartphones and tablets since June 2025 under the Energy Labelling Framework Regulation. Traders must display this score, along with information on durability, minimum software update periods and spare parts availability where producers make that information available, in a way that is clear and visible before a consumer completes a purchase, whether in a physical store or online.

From 27 September 2026, retailers must also display a harmonised notice informing consumers of their legal guarantee rights, prominently placed at points of sale such as near checkout counters or on retailer websites, alongside a separate voluntary harmonised label that producers can use to advertise commercial durability guarantees exceeding two years at no extra cost to consumers.

 

Existing Stock on Shelves Must Also Comply Starting Now

 

The Commission's guidance makes clear that the new rules apply to products already manufactured, distributed or sitting on retailer shelves before the 27 September 2026 application date, with no grace period for old stock. Traders who discover non-compliant claims or labels on existing inventory have practical remedies available, including covering or correcting claims with stickers or posting supplementary information near affected products in stores, though national enforcement authorities are expected to weigh proportionality and the reasonableness of a trader's compliance efforts when assessing individual cases. Businesses still selling products manufactured before the rules applied should treat packaging and marketing audits as an immediate priority rather than a future task, given enforcement now falls to national consumer protection authorities and courts across all 27 member states.

 

Source: European Commission