Directive (EU) 2024/825 of the European Parliament and of the Council on Empowering Consumers for the Green Transition, known as the ECGT Directive, represents a fundamental reform of European consumer law. Its main objective is to protect consumers from misleading environmental claims (greenwashing), opaque sustainability labels, and practices that lead to the premature obsolescence of products.
The directive amends two key EU regulations: Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights. It applies to all merchants and manufacturers who offer goods, services, or digital content to consumers (B2C) on the European market. For small and medium-sized enterprises, this primarily means the need to thoroughly review and revise their marketing communications, product information, packaging, online stores, and warranty terms.
The directive was adopted in February 2024, and member states were required to transpose it into their national legislation by March 27, 2026. The new rules will be fully enforced as of September 27, 2026. Companies affected by the directive should therefore ensure that their business practices and product information are fully compliant with the new requirements.
The ECGT Directive expands the blacklist of unfair commercial practices (Annex I to Directive 2005/29/EC) to include new explicit prohibitions that apply regardless of the circumstances:
It is prohibited to use general claims such as “eco-friendly,” “green,” “natural,” “biodegradable,” “climate-friendly” or “energy-efficient” unless the company can demonstrate the corresponding environmental quality, for example through recognized certification (such as the official EU Ecolabel, a certified system under ISO 14024 Type I, or the highest energy-labeling class, A). The prohibition does not apply if the specification of the claim is stated clearly and visibly on the same medium (e.g., “100% energy from renewable sources used in the production of the packaging”).
The directive prohibits claims that a product or service has a neutral, reduced, or positive impact on the climate (e.g., “climate-neutral,” “CO₂-neutral,” “carbon-offset”), if such a claim is based on the inclusion of emission allowances and offset projects outside the product’s value chain.
An environmental benefit pertaining only to a specific part of a product (e.g., only recyclable packaging) cannot be presented as if it applied to the entire product. Similarly, the use of renewable energy at a single facility cannot be presented as evidence of the environmental sustainability of the entire company.
Statements regarding future environmental performance (e.g., “achieving net-zero by 2030”) are prohibited unless they are supported by a detailed, realistic implementation plan with verifiable targets, allocated budgets, and regular verification by an independent third-party expert.
Companies may not use voluntary sustainability labels unless they are based on certification by an independent third party or have been established by public authorities. The certification system must be transparent, open to all businesses under the same conditions, and subject to objective oversight.
It is not possible to present as a competitive advantage the fact that a product does not contain a substance whose use is prohibited by law in all products of that category within the EU. Such a claim is now considered an unfair trade practice.
The ECGT Directive does not focus solely on greenwashing. The new rules also address the premature obsolescence of products.
The directive also introduces new pre-contractual information requirements. Sellers will be required to provide consumers with information—for example, regarding product lifespan, repairability, or software updates—before the contract is concluded.
The new requirements include, in particular:
To avoid the risk of penalties for unfair commercial practices and misleading consumers, small and medium-sized enterprises should now verify whether their marketing and product information comply with the new rules, which will be fully effective as of September 27, 2026.
✔ Step 1: Audit marketing and product claims
Review all packaging, websites, online stores, social media, and advertising materials. Focus on claims containing words such as “eco,” “sustainable,” “green,” or “neutral.” If you do not have official certification (e.g., the EU Ecolabel), remove the claims or replace them with specific and verifiable details, such as “the packaging contains 80% recycled plastic.”
✔ Step 2: End CO₂ neutrality claims based on offsets
Stop promoting products or services as “climate neutral” or “carbon offset” if these claims are based on the purchase of trees or external emission allowances.
✔ Step 3: Review sustainability labels and logos
Check all logos and environmental labels on your products. Only labels established by public authorities or based on independent third-party certification systems that meet the required criteria may be retained.
✔ Step 4: Preparing the e-shop and retail locations for the new warranty labels
Modify the product detail templates in the e-shop and at physical retail locations so that they display the Harmonized Notice (2-year statutory warranty) and the Harmonized Shelf Life Label.
✔ Step 5: Requesting Accurate Information from Suppliers and Manufacturers
As resellers, make sure to obtain the necessary information from your suppliers. Request accurate details from manufacturers regarding the guaranteed period for software updates, durability, and the availability of replacement parts.
Sustainability presents companies with new challenges and opportunities. At the Enterprise Europe Network, we help small and medium-sized enterprises navigate European legislation, find suitable solutions, and take advantage of the opportunities associated with sustainable business practices.
Would you like to find out how we can help your company?
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