The EU ECGT Directive is the most significant change to green marketing law in a generation. Since Directive 2024/825/EU was published, we have fielded hundreds of questions from marketing teams, legal departments, and compliance officers trying to understand what it actually requires. This page compiles the 25 most common questions, answered clearly.
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Basics
1. What is the ECGT Directive?
ECGT stands for Empowering Consumers through Green Transition. Directive 2024/825/EU, adopted in February 2024, amends two existing EU consumer protection directives — the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU) — to address greenwashing specifically. It adds new environmental practices to the UCPD's list of commercial practices that are banned in all circumstances, tightens the rules on misleading environmental claims, and leaves penalties to each member state under the UCPD's existing penalty rules — the directive itself contains no penalty article.
2. When does ECGT take effect?
The directive was published in the Official Journal on 6 March 2024. Member states had until 27 March 2026 to adopt and publish their national measures, and those measures apply from 27 September 2026 — so the rules have been live since that date. See our 27 September 2026 explainer for what changed on the day.
3. Who does ECGT apply to?
ECGT applies to traders — any natural or legal person acting for purposes related to their trade, business, craft, or profession — who make environmental claims in the EU. This includes EU-based businesses and non-EU businesses that market to EU consumers. Size is not a relevant threshold: the directive has no SME or micro-enterprise exemption and no later application date for smaller firms.
4. What is the difference between ECGT and the Green Claims Directive?
ECGT and the Green Claims Directive (GCD) are related but separate instruments. ECGT amends existing consumer protection law to ban specific claims and require substantiation. The Green Claims Directive was a separate 2023 Commission proposal that would have added pre-approval of claims by accredited verifiers. In June 2025 the Commission announced its intention to withdraw it, and it is not law. ECGT is the instrument that applies, from 27 September 2026. See our full comparison for detail.
5. Does ECGT apply to B2B claims?
ECGT is primarily a B2C instrument — it amends consumer protection directives. However, B2B marketing materials, especially on public-facing websites, are within scope if they could influence consumer purchasing decisions. Claims in sustainability reports, investor communications, and supplier documentation are generally outside ECGT scope but may be subject to other EU legislation (CSRD, taxonomy regulation).
Banned Claims and Substantiation
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6. What green claims are banned under ECGT?
ECGT Annex I (as amended) lists the following as unfair commercial practices per se — meaning no context or substantiation makes them permissible:
- Generic environmental claims without a recognised EU ecolabel: "eco-friendly", "environmentally friendly", "green", "nature-friendly", "ecological"
- "Sustainable" or "sustainability" without substantiation via EU-recognised certification
- "Climate neutral", "carbon neutral", "net-zero" based solely on carbon offsetting without emissions reduction
- "Carbon positive", "climate positive" — these have no standardised meaning
- "Natural" used to imply environmental benefit when not substantiated
See the complete banned terms list with examples and compliant alternatives.
7. Can I still use "sustainable" if I have certifications?
Yes, but only if the certification is recognised under EU or national law as meeting the ECGT substantiation requirements. EU Ecolabel, organic certification (EC 834/2007 and successors), and EMAS qualify. Private certifications — even reputable ones — require careful assessment. A third-party certification that does not meet ECGT's requirements for independence and methodology does not rescue a claim. When in doubt, reference the specific certification explicitly: "certified EU Ecolabel" is permissible; "sustainable, certified by [private body]" may not be.
8. Are comparative claims still allowed?
Yes. Comparative environmental claims are not banned, but they are judged under the UCPD's misleading-practice rules (Articles 6 and 7), so a comparison that leaves out what is compared, how, and on what data is high-risk. If you run a service that compares products on environmental characteristics, Article 7(7) — inserted by Directive 2024/825 — makes the comparison method, the products compared and the measures to keep that information up to date material information. "30% lower carbon footprint than our 2020 model, based on lifecycle assessment per ISO 14044" is compliant. "Greener than before" is not.
9. Are future commitment claims ("net-zero by 2030") allowed?
Only with a plan behind them. Under UCPD Article 6(2)(d), as amended, a claim about future environmental performance is misleading unless it rests on clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan with measurable, time-bound targets, regularly verified by an independent third-party expert whose findings are made available to consumers. "Net-zero by 2030" with no such plan is exposed.
10. What counts as sufficient substantiation?
ECGT does not define a single standard but requires that substantiation be based on "recognised scientific evidence and assessment methods" and be available to regulators on request. In practice, accepted forms include: lifecycle assessments per ISO 14040/14044, third-party audited carbon footprint calculations per ISO 14064, and claims backed by recognised certification schemes. Internal calculations without third-party verification are weak substantiation for any significant claim.
11. Is it enough to link to a sustainability report?
A sustainability report helps but does not automatically substantiate a marketing claim. The specific data supporting each specific claim must be traceable and verifiable. A general link to a 100-page sustainability report does not meet the requirement if the relevant data is not clearly identified. Best practice: link to the specific page or section of the report and specify the metric.
Scope and Application
12. Does ECGT apply to social media posts?
Yes. Any commercial communication — including social media, influencer content commissioned by a brand, and digital advertising — that makes environmental claims is within scope. Brands are responsible for claims made on their behalf by influencers in paid partnerships.
13. Does ECGT apply to product packaging?
Yes. Physical packaging claims are within scope of ECGT alongside digital marketing. The Packaging and Packaging Waste Regulation (being finalised in parallel) adds additional requirements for packaging-specific claims. A claim like "100% recyclable" on packaging must be substantiated and must not imply the whole product cycle is sustainable if only the packaging is addressed.
14. Do sustainability labels from third parties need ECGT approval?
Not approval as such, but the label must qualify. UCPD Annex I point 2a, inserted by Directive 2024/825, bans in all circumstances displaying a sustainability label that is not based on a certification scheme or not established by public authorities. The directive defines what a certification scheme must offer, including third-party monitoring of compliance. Check the scheme behind every private label you display.
15. Does ECGT affect email marketing?
Yes. Email marketing that includes environmental claims — product newsletters, promotional emails, sustainability updates — is within scope. The same substantiation requirements apply as to website copy.
Enforcement and Penalties
16. What are the penalties under ECGT?
ECGT has no penalty article of its own. Its bans sit inside the UCPD, whose Article 13 requires each member state to set penalties that are effective, proportionate and dissuasive. The "at least 4% of annual turnover" maximum applies only to coordinated cross-border actions under Regulation (EU) 2017/2394, with a maximum of at least €2 million where turnover data is unavailable. Everything else depends on national law. See our penalties overview.
17. Which regulators enforce ECGT?
Enforcement is by national consumer protection authorities. Key bodies include: ACM (Netherlands), DGCCRF (France), Wettbewerbszentrale (Germany), CMA (UK — not EU but parallel legislation), AGCM (Italy), and CNMC (Spain). The European Commission coordinates via the Consumer Protection Cooperation network. Check your national authority's own guidance for its enforcement approach.
18. Can consumers sue under ECGT?
Yes, in two ways. UCPD Article 11a gives consumers harmed by unfair commercial practices access to remedies, including compensation and, where relevant, a price reduction or termination of the contract — and the ECGT bans are now part of the UCPD. Separately, the Representative Actions Directive (2020/1828/EU) lets qualified entities bring representative actions on behalf of consumers.
19. What happens if we self-report a violation?
Self-reporting (voluntary disclosure to the regulator before a complaint is received) is a mitigating factor under most national implementing legislation. UCPD Article 13(2) lists any action taken by the trader to mitigate or remedy the damage suffered by consumers among the criteria authorities take into account when setting a penalty. A documented compliance programme and audit trail shows that action.
20. Does ECGT apply to legacy content — articles and pages published before September 2026?
Yes, if it is still live. The directive contains no grandfather clause for marketing content published before 27 September 2026: a page from 2023 that is still online today is assessed against the current rules.
Compliance Practicalities
21. How do I audit my website for ECGT compliance?
Start with a scan using the GreenClaims Scanner to get a baseline picture of your current exposure. Then work through the audit checklist to systematically address issues by priority. For large sites, focus first on high-traffic pages and product pages — these carry the highest enforcement risk.
22. How long does compliance remediation take?
For a mid-size site, an initial audit and remediation of critical issues typically takes 4–8 weeks. The most time-consuming part is usually gathering and documenting the substantiation for existing claims — not the copy rewrites themselves. Plan for 2–4 weeks of internal data gathering before the writing work begins.
23. What is the simplest way to make existing claims compliant?
Three approaches work for most situations: (1) Replace generic claims with specific, quantified claims backed by data you already have. "Eco-friendly packaging" → "Packaging made from 80% recycled material, verified by [certification]." (2) Add scope limitations: "Our manufacturing process is certified carbon-neutral by [body], covering Scope 1 and 2 emissions." (3) Remove claims that cannot be substantiated and replace with factual product information. See the do/don't guide for worked examples.
24. Does the scanner tell me how to fix non-compliant claims?
Yes. The GreenClaims Scanner provides remediation suggestions alongside each flagged claim. These are generated by the same AI layer using ECGT-compliant reformulation patterns. They are starting points for human copywriters, not final copy — always have a compliance-aware person review before publishing.
25. Where can I find the most current ECGT compliance guidance?
Primary sources: the text of Directive 2024/825/EU (EUR-Lex), European Commission guidance documents (published via DG Justice), and national enforcement authority guidance notes. For practical marketing guidance, our ECGT compliance guide synthesises the regulatory requirements into actionable rules for marketing and legal teams.