EU Greenwashing Rules: How to Comply With the ECGT in 2026

From 27 September 2026, all Member States must apply national measures implementing the European Union (EU)’s new greenwashing rules, the Empowering Consumers for the Green Transition Directive (ECGT), Directive (EU) 2024/825. The directive strengthens EU consumer-protection rules on environmental marketing. It prohibits generic claims such as “eco-friendly”, “green,” or “biodegradable” unless the business can demonstrate recognised environmental performance relevant to the claim. It also bans claims that a product or brand has a neutral, reduced, or positive greenhouse gas impact where those claims are based on offsetting emissions outside the product’s value chain.

The ECGT is intended to help consumers make better-informed purchasing decisions, strengthen protection against misleading commercial practices and support a circular, clean and green economy. It does this by:

• restricting specified misleading environmental-marketing practices;
• improving pre-contractual information on durability, repairability and consumer guarantee rights; and
• strengthening the existing EU consumer-law framework.

How the ECGT works

The ECGT amends two existing directives: the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD).

Amendments to the Unfair Commercial Practices Directive (UCPD) add practices to its list of practices prohibited in all circumstances. These include making generic environmental claims without recognised excellent environmental performance; claiming that a product or trader has a neutral, reduced or positive greenhouse-gas impact based on offsetting outside the product’s value chain; presenting a claim about an entire product or business when it relates only to one aspect; and displaying sustainability labels that are not based on a qualifying certification scheme or established by a public authority.

Changes to the Consumer Rights Directive (CRD) introduce a standardised notice explaining consumers’ legal guarantee rights for goods. It also introduces a product-specific label where a producer offers, free of charge, a commercial durability guarantee that covers the entire product and lasts for more than two years. The CRD amendments also add pre-contractual information requirements on software updates, reparability and spare parts in the circumstances set out in the Directive.

A separate legislative proposal, the Green Claims Directive, would have introduced more detailed rules on substantiating environmental claims, including third-party verification. In June 2025, the Commission announced its intention to withdraw the proposal and the final trilogue was cancelled. However, the proposal has not been formally withdrawn and remains pending; it has not progressed since.

Who is impacted?

The ECGT applies to business-to-consumer commercial practices, including advertising, packaging, labelling, websites and point-of-sale material. It can therefore affect any business that markets to EU consumers, wherever the business is established, including businesses based in the UK or US.

Business-to-business communications generally fall outside the UCPD’s consumer-facing scope. Information that businesses are required by law to disclose, including in sustainability reporting, is not itself an “environmental claim” under the ECGT definition. However, content from a sustainability report that is reused in consumer-facing marketing may be subject to the ECGT and other consumer-protection rules.

How to comply with the ECGT

The central concept that underlies compliance with the ECGT is ensuring that claims are backed up by facts that can be evidenced.

• Make generic claims specific, or remove them. A 2020 European Commission study found that 40% of examined environmental claims were unsubstantiated. Generic claims such as “eco-friendly” are only permitted where a product holds the EU Ecolabel, an officially recognised EN ISO 14024 Type I ecolabel such as the Nordic Swan or Blue Angel, or meets top environmental performance under other EU law.
• Check sustainability labels. Sustainability labels must be established by a public authority or based on a certification scheme that meets the Directive’s requirements, including independent third-party monitoring.
• Support future environmental performance claims with a plan. Claims such as “net zero by 2040” require clear, objective, publicly available, and verifiable commitments, set out in a detailed and realistic implementation plan with measurable, time-bound targets. The plan must be regularly verified by an independent third-party expert, and the findings made available to consumers.
• Substantiate the claim actually being made. Claims should be accurate, capable of evidence and limited to the product, activity or business scope they describe. Life cycle data, including a product carbon footprint or an environmental product declaration where appropriate, may support substantiation.

What claims are restricted under the ECGT?

The ECGT builds on existing EU consumer-protection rules that have already been used against potentially misleading environmental marketing. For example, in April 2024, the European Commission and national consumer authorities contacted 20 airlines about environmental claims concerning emissions offsetting and sustainable aviation fuel. In March 2024, the Amsterdam District Court found several KLM advertisements misleading because of vague or overly general environmental claims. These cases pre-date the ECGT’s application date, but illustrate the direction of consumer-law enforcement.

Note: National implementation and enforcement mechanisms differ by country. The Commission’s national transposition database records measures notified by Member States.

How Zevero can help

Zevero can help businesses build evidence for environmental claims through Scope 1, 2, and 3 inventories and decarbonisation strategy support. This information can help businesses assess whether their marketing claims are specific, accurate and capable of substantiation. Get in touch to learn more.