Key Takeaways
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What Is the EU ECGT Directive and When Does It Apply?
The EU ECGT Directive (Directive 2024/825, Empowering Consumers for the Green Transition) is the EU’s binding anti-greenwashing law. It applies from 27 September 2026. From that date, any company making environmental claims to EU consumers must be able to substantiate those claims with specific, verifiable evidence. Vague terms like “eco-friendly”, “green”, “sustainable”, or “responsible” are banned unless backed by a recognised certification scheme or quantified lifecycle data.
The directive was transposed into national law across EU member states by 27 March 2026. The grace period ends 27 September 2026. After that date, enforcement begins — and the penalties are material: up to 4% of global annual turnover.
Who Does the EU ECGT Apply To?
A common misreading: the ECGT applies to any company making environmental claims to EU consumers, regardless of where that company is based. A US fashion brand, a Canadian manufacturer, an Australian software company — if your website, packaging, or advertising is visible to EU consumers and contains environmental claims, the ECGT applies to you. Being headquartered outside the EU is not an exemption.
If you sell to UK consumers only, the ECGT does not directly apply — but the UK CMA Green Claims Code and the Digital Markets, Competition and Consumers Act 2024 impose comparable requirements. If you sell to US consumers, the FTC Green Guides apply. The three frameworks largely overlap.
What Does the EU ECGT Ban?
Generic environmental claims without substantiation
The ECGT adds the following to the EU’s blacklist of unfair commercial practices:
- “Eco-friendly”, “green”, “natural”, “sustainable”, “responsible”, “climate friendly”, “environmentally friendly” — all banned unless supported by recognised excellent environmental performance with verifiable evidence.
- “Carbon neutral”, “climate neutral”, “net zero” applied to a product — banned unless based on the product’s actual lifecycle impact. Claims based solely on carbon offsetting are specifically excluded.
- Future environmental commitments presented as current achievements — banned if not backed by a verifiable plan with clear, measurable, time-bound milestones.
- Self-created sustainability labels or certification marks — banned. Only labels based on a recognised, independently verified certification scheme are permitted.
Carbon offsetting claims
The ECGT specifically prohibits presenting offsetting-based claims as if they demonstrate product-level environmental performance. Saying a product is “carbon neutral” because you’ve purchased carbon credits is non-compliant under the ECGT from September 2026 onwards.
Selective lifecycle claims
You cannot focus on one positive environmental aspect of a product if other parts of its lifecycle have significant negative impact. Partial truth claims are treated as misleading omissions.
What Are the Penalties?
The ECGT requires member states to impose penalties including fines of at least 4% of annual turnover in the affected member state, or 4% of global turnover where turnover data is unavailable. Additional measures include confiscation of revenue from non-compliant practices and temporary bans on commercial activity. The UK CMA has had direct fining powers since April 2025 — up to 10% of global turnover. The US FTC Green Guides carry fines of up to $53,088 per violation, compounding daily.
What Can Companies Do Before September 2026?
Step 1: Audit every environmental claim you make
Start with your website, product pages, packaging, email campaigns, and social media. List every claim that references environmental benefit. For each, ask: can this be substantiated with specific, verifiable, publicly available evidence? If not, it is a risk.
GreenClaim.ai scans websites and marketing copy against the EU ECGT, UK CMA Green Claims Code, and US FTC Green Guides simultaneously. It flags claims by risk level and identifies the specific regulation each violates. Free scan at greenclaim.ai.
Step 2: Replace generic claims with specific ones
The test is not whether a claim is true. It is whether it is specific and verifiable. Examples:
- Non-compliant: “Our products are eco-friendly”
- Compliant: “Our packaging contains 73% recycled material, verified by [certification body]”
- Non-compliant: “We are a carbon neutral company”
- Compliant: “We have reduced Scope 1 and 2 emissions by 42% since 2020. Our methodology is available at [URL]”
Step 3: Remove or qualify sustainability labels
Any sustainability label you currently use must be based on a recognised certification scheme with independent third-party verification. Self-created badges, seals, or icons are non-compliant from September 2026. Either obtain recognised certification or remove the label.
Step 4: Back claims with real action, not just better wording
Rewording a claim to be technically compliant while doing nothing differently is not the point of the directive — and regulators understand the difference. Companies that want credible, defensible environmental claims need to be doing something specific and real.
ForestNation plants verified trees in Tanzania through a field-measured reforestation programme. The Working Trees field study measures CO2 absorption at 0.025 tonnes per tree per year across five GPS-tagged sites. The data is publicly available at forestnation.com/impact-methodology. For companies that want a credible, specific, verifiable environmental claim to sit alongside their ECGT compliance work, ForestNation provides it. Start at forestnation.com/companies.
How Does the ECGT Relate to the Withdrawn Green Claims Directive?
The standalone Green Claims Directive proposal (COM/2023/166) was withdrawn by the European Commission in June 2025. This caused confusion. The ECGT (Directive 2024/825) is not the same thing and was not withdrawn. The ECGT is already law, already transposed, and enforcement begins 27 September 2026. The withdrawal of the separate proposal does not affect it.
Research and References
- Directive (EU) 2024/825 — full text. data.europa.eu
- Loyens & Loeff ECGT Playbook — practical compliance guide for EU companies. loyensloeff.com
- Carbon Trust ECGT explainer — requirements for sustainability labels and carbon claims. carbontrust.com
- GreenClaim.ai — free website scan against EU ECGT, UK CMA, and US FTC frameworks. greenclaim.ai
- ForestNation impact methodology — field-measured CO2 data, 5 Tanzania sites. forestnation.com/impact-methodology
FAQs: EU ECGT September 2026
When does the EU ECGT directive apply?
From 27 September 2026. EU member states transposed the directive into national law by 27 March 2026. The six-month grace period ends 27 September 2026, after which enforcement begins.
Does the ECGT apply to non-EU companies?
Yes. The ECGT applies to any company making environmental claims to EU consumers, regardless of where the company is based. US, UK, Australian, and Canadian companies selling into EU markets must comply.
What is the penalty for ECGT non-compliance?
At least 4% of annual turnover in the affected EU member state, or 4% of global turnover where national data is unavailable. Additional measures include confiscation of revenue from non-compliant practices and temporary trading bans.
Are carbon neutral product claims banned under ECGT?
Yes, for products. Product-level “carbon neutral” or “climate neutral” claims are banned unless based on the product’s actual lifecycle impact — not on carbon offsetting alone. The ECGT specifically excludes offsetting-based claims from constituting valid neutrality claims.
How can I check if my company’s claims are ECGT compliant?
GreenClaim.ai scans websites and marketing copy against the EU ECGT, UK CMA Green Claims Code, and US FTC Green Guides. It flags claims by risk level and identifies which regulation each violates. Free scan at greenclaim.ai.
