The EU Green Claims Ban is the common name for Directive (EU) 2024/825, formally the Empowering Consumers for the Green Transition Directive (ECGT). It prohibits generic environmental claims like "eco-friendly" and offset-based "climate neutral" labels in business-to-consumer communications across the EU. National laws implementing the directive apply from 27 September 2026, with no exemption for small businesses. If you sell into the EU, every claim on your packaging, website, and marketing materials needs to be reviewed before that date.
What Is the EU Green Claims Ban (ECGT)?
The EU Green Claims Ban refers to Directive (EU) 2024/825, signed on 28 February 2024 (after Parliament's adoption on 17 January 2024) and published in the Official Journal on 6 March 2024. Its full title is the Directive amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information. The standard short forms are ECGT and "Empowering Consumers Directive".
The ECGT works by amending two existing pieces of EU consumer protection law: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). Most of its impact comes from new entries added to Annex I of the UCPD, the so-called "blacklist" of commercial practices considered unfair in all circumstances. Practices on this list are prohibited per se, with no need for a case-by-case assessment of consumer harm.
This matters because Annex I prohibitions apply directly. A regulator does not have to prove that a specific consumer was misled. The practice is unlawful as soon as it is used.
When Does the ECGT Apply?
The directive entered into force on 27 March 2024, twenty days after publication. From that date, two clocks started running:
| Date | What Happens |
|---|---|
| 27 March 2024 | Directive enters into force |
| 27 March 2026 | Deadline for Member States to transpose it into national law |
| 27 September 2026 | National laws apply to traders. Enforcement begins |
The application date is the one that matters operationally. From 27 September 2026, every Member State is required to be enforcing the new rules through its national consumer protection authority. France's DGCCRF, the Netherlands' ACM, Italy's AGCM, and equivalent authorities in every other Member State will treat banned claims as actionable infringements.
Packaging, marketing materials, and website copy take months to revise. New production runs and new marketing campaigns from 27 September 2026 onward must comply. The directive itself contains no express grandfather clause for existing inventory; how transitional stock is treated will depend on each Member State's transposition law. Do not assume a default grace period for products already in your warehouse.
What Specifically Does the ECGT Ban?
The directive adds new prohibited practices to the UCPD blacklist. The most consequential changes for brands:
1. Generic Environmental Claims Without Substantiation
Words like "eco", "green", "environmentally friendly", "natural", "biodegradable", "climate friendly", "energy efficient", and "sustainable" are banned when used as generic claims about a product, brand, or company unless the trader can demonstrate "recognised excellent environmental performance" relevant to the claim.
"Recognised excellent environmental performance" is a high bar. The directive's recitals indicate this should typically be demonstrated through compliance with EU Ecolabel Regulation (EC) No 66/2010, a comparable national or regional environmental labelling scheme officially recognised under Member State law, or top-tier performance in the relevant environmental aspect (for example, the highest energy efficiency class).
In practice, a small fashion brand should not assume words like "sustainable" or "eco-friendly" can stay on a t-shirt unless the t-shirt holds a recognised certification or its environmental performance is documented at a comparable level. The exact threshold will be tested through Member State enforcement after September 2026.
2. "Climate Neutral" Claims Based on Offsetting
This prohibition has drawn the most industry attention. Claims such as "climate neutral", "carbon neutral", "CO2 neutral certified", "carbon positive", "climate net zero", "climate compensated", "reduced climate impact", and "limited CO2 footprint" are banned when those claims are based on greenhouse gas emission offsetting outside the product's own value chain.
Buying carbon credits to offset emissions and then labelling the product "climate neutral" is no longer permitted. The claim is only allowed if the actual lifecycle emissions of the product are climate neutral on their own merits, through emission reductions inside the value chain rather than external offsets.
This provision invalidates much of the climate marketing currently used in fashion, food, electronics, and consumer goods.
3. Sustainability Labels Without a Certification Scheme
Brand-created or industry-created sustainability badges that are not based on a recognised certification scheme (and not established by public authorities) are banned. A brand cannot invent its own internal "sustainability star rating" and place it on packaging unless that rating is governed by an external certification scheme with independent verification.
This affects in-house sustainability programmes that many large retailers and brands have rolled out over the past five years.
4. Future Environmental Commitments Without Proof
Aspirational claims like "net zero by 2030" or "climate positive by 2040" are banned unless they are accompanied by clear, objective, publicly available, and verifiable commitments. That includes a detailed and realistic implementation plan with measurable, time-bound targets, and independent third-party monitoring of progress.
A net-zero pledge with no published roadmap and no independent verification will become an actionable infringement.
5. Other Practices Added to the Blacklist
The directive also adds a set of related prohibitions that target premature obsolescence and product durability claims:
- Presenting a product as repairable when it is not
- Prompting consumers to replace consumables (such as printer ink) earlier than technically necessary
- Presenting software updates as required when they reduce product functionality
- Making unsubstantiated claims about a product's expected lifetime or usage cycles
- Presenting features required by EU law as a distinguishing feature of the trader's offer
The European Commission's sustainable consumption page links to its full Q&A guidance on the new prohibited practices.
Does the ECGT Apply to Small Brands?
Yes. The ECGT contains no SME exemption. It applies to all traders engaged in business-to-consumer commercial communications in the EU, regardless of company size or place of establishment. A two-person brand selling handmade textiles into Germany via Etsy is subject to exactly the same prohibitions as a multinational retailer.
This contrasts sharply with other recent EU sustainability legislation. The Corporate Sustainability Reporting Directive (CSRD) has size thresholds. The Corporate Sustainability Due Diligence Directive (CSDDD) has size thresholds. The withdrawn Green Claims Directive proposal would have included a micro-enterprise exemption. The ECGT does not.
The scope is structural: because the ECGT works through the UCPD framework, it inherits the UCPD's universal scope. The UCPD applies to all B2C commercial communications, full stop.
The ECGT applies to all commercial communications targeted at EU consumers, including those from sellers established outside the EU. A US or Turkish brand selling into the EU through its own website, a marketplace, or a fulfilment service is within scope. National enforcement authorities have jurisdiction under the CPC Regulation (EU) 2017/2394 for cross-border infringements affecting EU consumers.
ECGT vs the Green Claims Directive: How They Differ
Most coverage conflates the ECGT with another piece of legislation. The EU has been developing two separate green-claims laws in parallel, and they are routinely confused in news coverage.
| ECGT (Directive 2024/825) | Green Claims Directive (proposed) | |
|---|---|---|
| Status | Adopted, in force, applies September 2026 | Proposal, withdrawal announced June 2025 |
| Reference | OJ L of 6 March 2024 | COM(2023) 166 |
| Approach | Adds prohibitions to the UCPD blacklist | Would have required ex-ante substantiation of claims |
| Substance | Bans generic claims and offset-based climate claims outright | Would have required Product Environmental Footprint substantiation and third-party verification of explicit claims |
| SME treatment | No exemption | Would have included a micro-enterprise exemption |
The ECGT is the law that actually applies. The Green Claims Directive would have been a separate, more burdensome regime requiring brands to scientifically substantiate every explicit environmental claim before making it. The Commission announced its intention to withdraw the GCD proposal in June 2025, and trilogue is currently paused. The proposal has not yet been formally withdrawn from the legislative register, but it is dormant.
If you read industry coverage referring to "the EU Green Claims Directive" applying in September 2026, the article almost certainly means the ECGT and is using the wrong name.
How Will the ECGT Be Enforced?
The ECGT does not introduce a new enforcement regime. It operates within the existing UCPD framework, which means:
- National consumer protection authorities in each Member State are the primary enforcers. France: DGCCRF. Netherlands: ACM. Italy: AGCM. Germany: a combination of the Bundeskartellamt and Land-level consumer protection authorities. Member State competent authorities are listed on the European Commission's CPC page.
- Penalties are set by Member States under Article 13 of the UCPD (as amended by the Omnibus Directive (EU) 2019/2161). For widespread cross-border infringements, fines can reach up to 4% of annual turnover in the relevant Member State(s), or at least €2 million where turnover cannot be ascertained.
- Cross-border enforcement is coordinated through the Consumer Protection Cooperation (CPC) Network. A complaint filed in one Member State can trigger coordinated action across multiple jurisdictions.
- Collective redress is available under Directive (EU) 2020/1828, allowing qualified consumer organisations to bring representative actions.
CPC coordination plus percentage-of-turnover fines means the practical enforcement risk for a brand selling across several Member States is materially higher than the single-jurisdiction risk would suggest.
What This Means for DPP Strategy
The ECGT does not directly mention the ESPR (Regulation (EU) 2024/1781) or the Digital Product Passport. The two regulations target different things: the ECGT polices the marketing claim, while the ESPR mandates structured product data. But there is a real overlap in practice.
If a brand wants to make any environmental claim that survives the ECGT, the claim has to be backed by verifiable, traceable data about the product. That is exactly what a DPP is designed to hold: material composition, supplier provenance, certification references, and lifecycle environmental data. Brands that already have robust DPP data infrastructure (and the supplier relationships that feed it) will find ECGT compliance significantly easier than brands relying on marketing-led sustainability narratives.
This connection is analytical rather than legal. The ECGT does not require a DPP. But the substantiation infrastructure needed for credible environmental claims under the ECGT is largely the same infrastructure needed for DPP compliance. Brands building one are de facto building the other.
For brands under pressure on both tracks, the practical sequence is: invest in product data first, retire unverifiable claims second, then redesign marketing around the claims that the data can actually defend.
What Small Brands Should Do Before September 2026
Five steps, in order of urgency:
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Inventory every environmental claim currently used on packaging, hangtags, your website, social media, marketplace listings, and email marketing. Include the full word-for-word phrasing, where it appears, and which products it covers.
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Strike the absolute prohibitions. Remove "climate neutral" labels backed by offsetting, generic "eco/green/sustainable" claims without recognised certification, and any in-house sustainability badges not based on an external certification scheme. These cannot be saved with footnotes.
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Audit certifications and labels. For any claim you want to keep, confirm the certification scheme is recognised: EU Ecolabel, an officially recognised national scheme, or a credible third-party scheme with independent verification. Self-certified or industry-association badges generally will not qualify.
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Build the substantiation file. For every retained claim, assemble the underlying evidence: certification documentation, lifecycle assessments, material declarations, supplier statements. Treat this as a compliance dossier the regulator may ask to see. Our DPP preparation checklist covers the data collection workflow that doubles as ECGT substantiation.
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Brief your suppliers and marketing team. New product copy, new packaging artwork, and new campaign briefs all need to be written under the new rules from now on. Repainting old claims onto new products won't work.
You have until 27 September 2026 to inventory claims, redesign packaging, and build substantiation files. Brands that wait until late August will be stuck with non-compliant inventory at the moment enforcement begins. For a wider view of how this fits into other 2026 deadlines, see our DPP timeline 2026–2030.
Frequently Asked Questions
What is the EU Green Claims Ban?
The EU Green Claims Ban is the common name for Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive (ECGT). It amends the Unfair Commercial Practices Directive to prohibit generic environmental claims, offset-based "climate neutral" labels, sustainability labels without a certification scheme, and unsubstantiated future environmental commitments. It applies to traders from 27 September 2026.
When does the ECGT apply?
The directive entered into force on 27 March 2024. EU Member States must transpose it into national law by 27 March 2026, and the national laws apply to traders from 27 September 2026. From that date, national consumer protection authorities can enforce the new prohibitions.
Can I still say my product is climate neutral after September 2026?
Only if the claim is not based on greenhouse gas offsetting outside the product's value chain. "Climate neutral" claims based on buying carbon credits are banned. The label is only permitted if the product's actual lifecycle emissions are neutral through reductions within the value chain, and even then the claim must be verifiable and substantiated.
Is there a small business exemption from the ECGT?
No. The ECGT contains no SME exemption. It applies to all traders engaged in business-to-consumer commercial communications in the EU, regardless of company size or place of establishment. This contrasts with the proposed Green Claims Directive, which would have exempted micro-enterprises and was announced for withdrawal in June 2025.
How is the ECGT different from the Green Claims Directive?
The ECGT (Directive 2024/825) is adopted, in force, and applies September 2026. It prohibits specific claims by adding them to the UCPD blacklist. The Green Claims Directive (COM(2023) 166) was a separate Commission proposal that would have required ex-ante substantiation and third-party verification of explicit environmental claims; the Commission announced its intention to withdraw the proposal in June 2025. Coverage that uses the names interchangeably is incorrect.
What are the penalties for ECGT non-compliance?
Penalties are set by each Member State under Article 13 of the UCPD (as amended by Directive (EU) 2019/2161). For widespread cross-border infringements, fines can reach up to 4% of annual turnover in the relevant Member States, or at least €2 million where turnover cannot be ascertained. Member States may also impose corrective orders, product recalls, and publication of judgments.
Does the ECGT require a Digital Product Passport?
No. The ECGT does not mention the ESPR or DPPs. But the substantiation infrastructure needed to defend environmental claims under the ECGT (verifiable material data, supplier provenance, certification references) is largely the same infrastructure needed for DPP compliance. Brands building one are effectively building the other.
