ECGT is Live: What Changes for Green Claims from Today
From today, 27 September 2026, a lot of familiar green marketing becomes a legal problem in the EU.
The Empowering Consumers for the Green Transition Directive (ECGT, sometimes called EmpCo) now applies. It amends the Unfair Commercial Practices Directive. That matters, because it means certain claims are no longer judged case by case. They are conditionally banned.
Most of the attention over the last two years went to the Green Claims Directive. That stalled in 2025. ECGT didn't. It was agreed in 2024, and it is the rule that bites now.
If you sell to EU consumers, this applies to you. Not just the big brands.
What's now banned outright
ECGT adds new practices to the EU's consumer-law blacklist. For most marketing teams, four matter most.
1. Generic claims. "Eco-friendly", "green", "sustainable", "climate friendly". These are out unless you can show recognised excellent environmental performance. In practice that means the EU Ecolabel, an officially recognised ISO 14024 ecolabel, or top performance under relevant EU law. Your own internal assessment doesn't count.
2. Whole-product claims for a partial improvement. If the recycled content is in the packaging, you can't imply the product is better. If one factory runs on renewables, you can't imply the business does. Say what's true, at the level it's true.
3. Offset-based neutrality claims. "Carbon neutral", "climate neutral", "CO₂ compensated" — where the claim relies on offsetting, it is banned at product level. This is the one that will catch the most companies off guard, because many were told these claims were fine with the right certificate. Company-level offset claims aren't on the blacklist, but they're still judged under the general rules on misleading claims.
4. Self-made labels. Sustainability labels now have to be based on a certification scheme with independent third-party verification, or set up by a public authority. And a "label" is broader than you think. A green leaf in a circle, designed to look like a badge, can count.
There's also a quieter one: presenting legal requirements as a selling point. If every product in your category must meet a standard, you can't market meeting it as a differentiator.
What's allowed, but only with proof
Future claims. "Net zero by 2040" isn't banned. But it now needs a clear, public, verifiable commitment behind it. That means a detailed implementation plan, measurable and time-bound targets, and regular checks by an independent third party. Consumers must be able to see the findings.
A target on a slide is not a plan.
Comparisons. If you compare products on environmental or social grounds, you must disclose the method, what was compared, and how the information is kept up to date.
Durability and repair. Claiming a product lasts longer than it does, or is repairable when it isn't, is now blacklisted. New information duties on durability and repair also sit alongside the claims rules. For most service businesses this is less relevant. For anyone selling physical goods, it isn't.
What this means if you're an SME
The temptation is to wait. Only a handful of member states transposed on time. In May 2026 the Commission opened infringement proceedings against 20 of them. Surely enforcement will be slow?
Maybe. But I wouldn't plan around it.
The rules apply to what EU consumers see, wherever you're based. Your website, packaging, product pages and social posts don't change by country. For widespread cross-border breaches, fines can reach 4% of annual turnover, or more where national law allows. And ECGT sits within the EU's representative actions regime, so consumer groups can bring claims too. Regulators aren't the only risk.
If you're in the UK and only sell in the UK, ECGT doesn't apply directly. But the CMA's Green Claims Code covers much the same ground, and since April 2025 the CMA can fine up to 10% of global turnover for consumer law breaches. Different law, same direction.
The bigger shift is this. Before, the question was "could this mislead?" That was arguable. Now, for the blacklisted claims, there's nothing to argue. Using the word is the breach.
For a small business that's actually useful. The rules are clearer than they've ever been. You don't need a legal team to spot "eco-friendly" on your homepage.
What to do this week
You don't need a transformation programme. You need an hour and a list.
Search your own content for: sustainable, eco, green, eco-friendly, climate friendly, carbon neutral, climate neutral, net zero, planet-friendly, responsible. Website, packaging, product listings, social bios, sales decks.
Delete or narrow every generic claim. Replace "sustainable packaging" with what's true: "box made from 80% recycled cardboard".
Pull any product-level neutrality claim that relies on offsets. You can still talk about the projects you fund. Just don't say they make the product neutral.
Check every badge and icon. If it isn't a certification with third-party verification, or a public scheme, remove it. That includes the leaf you designed in-house.
Stress-test your targets. For each future claim, can you point to a published plan, interim milestones and an independent verifier? If not, take it down until you can.
Brief whoever writes your copy. Agencies, freelancers, the sales team. Most breaches will come from someone who didn't know the rules changed.
The point
ECGT doesn't stop you talking about sustainability. It stops you being vague about it.
That's a good thing. Specific claims were always more credible. Now they're also the only ones that are safe.
If you want a second pair of eyes on your claims before a regulator or a competitor looks at them, that's what Claim Check is for. Get in touch.
This post is general information, not legal advice. National rules vary while transposition catches up, so check the position in the markets you sell into.
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