27 March 2026 was the deadline for the Directive (EU) 2024/825 on Empowering Consumers for the Green Transition (ECGT Directive) to be transposed to national EU member legislation. The countdown has begun to 27 September 2026 when it comes into effect. But what does this mean for businesses and how should they prepare for it?
 

What is the ECGT Directive?

The ECGT Directive primarily amends two existing consumer directives: the Unfair Commercial Practices Directive (Directive 2005/29/EC, UCPD) and the Consumer Rights Directive (Directive 2011/83/EU, CRD). It seeks to enable consumers in the EU to make informed purchasing decisions that contribute to more sustainable consumption practices. 

The Carbon Trust Group has been preparing for and encouraging legislation like the ECGT for many years, building awareness and expertise while continuously evolving and strengthening our label claims to ensure they remain credible, relevant and compliant in a changing regulatory and consumer landscape. 

As of today, the Carbon Trust Scheme Owner (CTSO), a legally independent subsidiary of the Carbon Trust Group, is compliant with the ECGT Directive based on the published information. We have confirmed the structures and processes required by the legislation, and are operating in accordance with these.

Find out more about the requirements for a certification scheme and the actions the Carbon Trust Group and the Carbon Trust Scheme Owner have taken to align.
 

How the Carbon Trust Scheme Owner aligns with the ECGT Directive:

When?

• 27 March 2026: Deadline for the ECGT Directive to be transposed to national legislation across EU member states.
• 27 September 2026: The ECGT comes into effect and companies that do not comply, may be liable for penalties. This means that any product on the shelf or any website accessible to EU consumers must comply with the new rules.

What will change?

The amendments under the ECGT Directive do not change the scope and logic of intervention of the two existing Directives, but introduce targeted changes, to, for example, better regulate vague and misleading environmental claims and sustainability labels. While the requirements are extensive, they centre on a few critical areas:

1. Ban on greenwashing and social washing, and prohibition of generic environmental claims: The ECGT Directive expands the scope of misleading commercial practices to vague, unsubstantiated, or unverifiable ESG communications – including those related to circularity, durability, and reparability. In most cases, terms such as 'eco-friendly', 'green', or 'climate neutral' are prohibited. Read our top tips on communicating about your climate action factually.
2. Regulation of sustainability labels: Companies may only use sustainability labels that are based on a recognised certification scheme (see below) or established by a public authority. Self-created certification schemes or unverifiable labels are prohibited from 27 September 2026.
3. Introduction of certification scheme requirements: The ECGT Directive sets minimum criteria for what qualifies as a recognised certification scheme, including requirements relating to transparency, impartiality, and regular third-party verification. Certification schemes provide assurance that a product, process, or business is compliant with specified requirements (as set out in Article 2(1)(s)).
4. Forward-looking claims require implementation plans: Claims about future environmental performance (e.g. 'Net Zero by 2040') must be supported by a detailed, realistic implementation plan, including measurable targets, allocated resources, and third-party verification.
5. Continuous substantiation and monitoring: Companies must maintain up-to-date substantiation for all ESG communications and ensure consistency across all communications. Compliance is not a one-off, check-the-box exercise but requires ongoing diligence.
6. Enhanced enforcement powers: National authorities are empowered to impose significant penalties for non-compliance, including fines.

The information provided in this insight is for informational or educational purposes only. The content does not constitute legal advice. For a full picture of the ECGT Directive and its implications, refer to the EU Directive legislation.
 

Who will it impact?

The ECGT may apply to your company if you:

• Communicate with consumers in the EU
• Market products or services in the EU
• Use sustainability-related claims, labels, or certifications in business-to-consumer (B2C) communications

A company does not need to be headquartered in the EU to be impacted, and it may apply based on where and how a company communicates with consumers, similar to other consumer protection laws. 

Although the legal scope of the ECGT Directive is focused on B2C commercial practices (i.e. advertising, labelling, and marketing directed at consumers), its impact may extend beyond that. For example, some member states may extend its protection to B2B relations at the national level, as is happening in Germany. Also retailers that sell non-compliant products in the EU from 27 September, could be fined. Though corporate sustainability reports are not typically in scope, as they are not part of B2C commercial practices, it may become relevant if businesses use information from the reports in activities directed at consumers. 

It appears the expectation for transparency is converging across regulations in the EU and beyond hence we expect that businesses, investors, and regulators may increasingly refer to the ECGT Directive’s framework when evaluating the credibility of ESG communications. Our recommendation therefore is to always ensure your ESG communications are specific, substantiated, transparent and consistent, whether the claim appears on product packaging or in investor disclosures. 

Unsure if your company could be impacted? Get in touch.
 

How will it impact companies?

The ECGT Directive is expected to have implications across multiple functions within an organisation, including data, communications, procurement and legal. 

• Data and measurement: Under the ECGT Directive, environmental claims must be supported by strong evidence. Organisations will need robust carbon footprints, third-party assurance, and consequently a clear understanding of emissions hotspots. This data will increasingly inform R&D, decarbonisation planning, sales conversations and consumer communications.
• Marketing and communications: Green claims and environmental labels will be subject to stricter rules on credibility, transparency and verification. From 27 September 2026, consumer-facing claims will need to be supported by certification or sustainability labelling schemes with independent third-party verification, creating a greater opportunity for brand differentiation and to communicate climate action with greater confidence.
• Procurement and supply chains: Suppliers may face increased requests from retail and commercial partners for primary data or recognised certification schemes to substantiate environmental claims. This will likely raise expectations on data availability, accuracy and traceability across value chains.
• Legal and risk management: Enforcement and penalties will vary by member state, with fines potentially reaching up to 4% of annual turnover. Organisations will need to understand the regulations for their respective market, upskill cross-functional teams, and prepare for contractual implications, including potential indemnification requests related to greenwashing risks. 
   

How will it impact consumers?

By improving the availability and consistency of information on product durability, repairability and environmental performance, the ECGT Directive is expected to help consumers make more informed purchasing decisions that align with their values. For example, evidence suggests that products which communicate their sustainability credentials, perform better commercially on retail platforms like Amazon (average of +15% sales uplift in Europe within the first year for products on Amazon’s Climate Pledge Friendly programme). 
 

What advice do you have for companies in the run up to 27 September 2026?

By proactively engaging with the ECGT Directive, businesses can build brand trust, equity and consumer preference. Clear, credible environmental information is becoming a differentiator at the point of purchase, as many consumers continue to seek out sustainability cues on packaging. Early alignment can also help reduce exposure to reputational and legal risk, and respond to growing expectations from regulators, investors and other stakeholders. 

In light of the requirements for marketing processes and supply chain structures, early assessment of potential gaps can help organisations prepare for timely compliance. Practical steps to help you prepare include: 

1. Continue monitoring EU consumer protection regulations, and other relevant sector regulations that may apply. Understand the nuances across relevant member states.
2. Set up strong cross-functional working groups across legal, sustainability, compliance, and communications teams to ensure that ESG claims are not only accurate, but also coherent across all channels. Develop suitable processes to provide information on updates, reparability and durability.
3. Do an internal assessment on whether you are exposed to ECGT by:
   a.    Mapping all EU consumer communication touchpoints
   b.    Create a list of the various B2C claims and labels being used
   c.    Check the use of implicit claims such as icons, symbols, images, or artwork that could be perceived as or associated with environmental sustainability (e.g. green leaf, trees)
   d.    Engage with your buyers and suppliers to understand changes in their needs
4. Check whether the labels in use will meet the requirements of an independent certification scheme by 27 September 2026 like the Carbon Trust label scheme; otherwise, these labels should be removed or replaced in due course.
5. Identify third-party verification partners to substantiate environmental data underpinning existing claims, and develop robust implementation plans for future climate target-related claims, supported by a clear and transparent communication strategy. Get in touch for support.
6. Create a timeline for amendments needed to data collection, communications, and assurance requirements to meet the 27 September 2026 deadline.
7. Review your environmental claims to ensure those directed to consumers are, where relevant:
   a.    Specific, and those specifications are provided next to, or as part of, the claim, in a clear and prominent manner, on the same medium
   b.    Backed by a qualifying certification scheme
   c.    Scoped according to the aspects covered
   d.    Do not link to product-level offsetting
   e.    Only future-focused if backed by a detailed independently verified implementation plan
    

How can the Carbon Trust support?

The Carbon Trust Scheme Owner (CTSO) continues to evolve and improve its label claims, so they remain credible, relevant and compliant in a changing regulatory and consumer landscape. Since launching the world’s first product carbon footprint label in 2007, the Carbon Trust has verified more than 37,000 products across 40 countries to become the most recognised carbon footprint globally by consumers.
Its label portfolio is supported by close monitoring of regulatory developments in the green claims space to ensure continued alignment as rules evolve. The Carbon Trust also has a dedicated marketing and technical team for carbon footprint labelling, undertaking regular consumer research and focus groups to maintain a strong understanding of consumer expectations around carbon footprint labelling.

As of today, we meet the legal requirements for being a valid sustainability label in the EU.

Find out more about carbon footprint labelling or get in touch with our experts.