Short answerFrom 27 September 2026, the ECGT Directive (EU) 2024/825 on consumers and the green transition bans generic environmental claims such as 'eco-friendly' without recognised excellent performance, labels not based on certification schemes or public authorities, and offsetting-based neutrality claims. Product teams should manage every claim as a governed, evidenced record in PIM.
Key takeaways
- Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive and applies from 27 September 2026 across all consumer-facing product content.
- Claims that a product has a neutral, reduced or positive climate impact based on greenhouse gas offsetting are prohibited outright from that date.
- The separate Green Claims Directive proposal stalled in June 2025 and has not been adopted, so substantiation rules beyond the ECGT bans remain uncertain at EU level.
The ECGT Directive turns claim wording into a compliance risk
The ECGT Directive (EU) 2024/825, on strengthening consumers for the green transition, amends the Unfair Commercial Practices Directive and the Consumer Rights Directive, and member states apply it from 27 September 2026. It adds specific practices to the blacklist of commercial practices considered unfair in all circumstances. A blacklisted practice needs no case-by-case assessment of consumer harm, so enforcement becomes simpler for authorities. Every product description, marketplace listing, packaging artwork file and social post that carries an environmental statement is in scope.
Four categories of claim are banned outright
The directive targets the wording most common in product content today.
- Generic environmental claims: terms such as 'environmentally friendly', 'green', 'eco', 'natural', 'climate friendly' or 'biodegradable' without recognised excellent environmental performance relevant to the claim, such as an EU Ecolabel or a qualifying ISO Type I label.
- Uncertified sustainability labels: labels not based on a certification scheme or established by public authorities. Self-created logos and in-house badges are the main casualties.
- Whole-product claims for partial attributes: a claim about the entire product or business when it applies only to one aspect, such as recycled content in the packaging only.
- Offsetting-based neutrality claims: claims that a product has a neutral, reduced or positive greenhouse gas impact based on offsetting outside the value chain.
The directive also bans presenting legal requirements as a distinctive feature and covers future performance claims, which need a detailed, independently verified implementation plan. Specific claims remain possible, for example '70% recycled polyester in the outer fabric', provided the evidence holds. Precision becomes the safest content strategy: a claim names the attribute, the component it applies to and the measured value.
Durability and repairability information joins the product record
The directive extends pre-contractual information to durability and repair. Traders must inform consumers about the legal guarantee of conformity and, where the producer offers one, any commercial guarantee of durability beyond two years. A harmonised label and notice will display this information. For goods with digital elements, information on the period of free software updates becomes relevant. Planned obsolescence practices, such as withholding information on features introduced to limit durability, are also blacklisted.
These duties create new attributes: commercial durability guarantee period, software update period, availability of spare parts and repairability score where one exists. They overlap with ecodesign requirements described in the ESPR ecodesign regulation article, so a single attribute definition should serve both.
The Green Claims Directive remains uncertain
The Green Claims Directive proposal, published in March 2023, aimed to add ex-ante substantiation and third-party verification for explicit claims. In June 2025, the Commission signalled its intention to withdraw the proposal and the final trilogue was cancelled, although the Commission later stated that it had not formally withdrawn it. The Commission's 2026 work programme still lists the file as pending, no trilogue had resumed by October 2026, and national authorities continue to apply existing unfair commercial practices law alongside the new ECGT bans. Organisations should prepare substantiation evidence anyway, because consumer authorities and courts already expect claims to be verifiable.
Govern claims as structured, evidenced data
Claims belong in a governed library inside the PIM, separate from free-text descriptions. The table shows a workable claim record.
| Field | Purpose |
|---|---|
| Claim code and approved wording per locale | Prevents uncontrolled rephrasing |
| Scope (product, component, packaging) | Avoids whole-product misstatements |
| Evidence reference and expiry date | Links test reports, certificates or footprint studies |
| Label or certification scheme | Confirms eligibility for logos |
| Approver and approval date | Creates the audit trail |
| Permitted markets and channels | Handles national differences |
Three controls follow from this model. First, block banned generic terms in descriptions with automated text rules, including AI-generated copy, as discussed in generative AI product descriptions governance. Second, expire claims automatically when the evidence date passes. Third, route new claims through legal and sustainability review before release, using the workflow patterns in product data quality governance. Claims built on carbon figures should reference the method and boundary set out in product carbon footprint data. A first content audit typically finds banned wording across an estimated 10 to 30% of listings in categories with heavy sustainability marketing, so start with high-traffic product families before 27 September 2026.
Frequently asked questions
When does the ECGT Directive apply?
Directive (EU) 2024/825 entered into force in March 2024. Member states had to transpose it by 27 March 2026 and must apply the new rules from 27 September 2026. From that date, blacklisted practices such as generic environmental claims and offsetting-based neutrality claims are prohibited in consumer-facing communication.
Can products still be called 'carbon neutral'?
Claims that a product has a neutral, reduced or positive greenhouse gas impact based on offsetting are banned from 27 September 2026. Companies may still communicate genuine reductions within their own value chain, or describe offsetting investments separately, provided the wording is specific, accurate and supported by evidence.
What happened to the Green Claims Directive?
The Green Claims Directive proposal of March 2023 stalled in June 2025 when the Commission signalled its intention to withdraw it and the final trilogue was cancelled. The Commission later said it had not formally withdrawn the proposal, which its 2026 work programme still lists as pending, with no agreement or resumed trilogue by October 2026. The ECGT Directive bans still apply, and existing unfair commercial practices law continues to require that explicit claims are accurate and verifiable.