If your product copy uses the word “sustainable” anywhere — packaging, website, a hangtag — 27 September 2026 is worth a diary note. That’s when the EU’s new anti-greenwashing law, ECGT, starts applying across all 27 Member States. It doesn’t care how big you are.
This isn’t a scare piece. Most small brands making honest products don’t need a compliance department for this — they need an afternoon with their own website and packaging, a red pen, and a plan for the handful of claims that need backing up. Here is what the rule actually says, and a checklist for the next couple of months.
What ECGT actually is
ECGT — the Empowering Consumers for the Green Transition Directive, formally Directive (EU) 2024/825 — amends the EU Unfair Commercial Practices Directive. It entered into force on 26 March 2024, and after a national transposition period, it applies uniformly across the EU from 27 September 2026. From that date, generic environmental claims are treated as unfair commercial practices unless they can be substantiated with recognised, verifiable evidence.
We cover the full timeline, the complete list of banned practices and the penalty regime in detail on our ECGT guide page — this post is the shorter, practical version aimed specifically at what a small brand should do before the date lands.
What's actually banned
The Directive doesn’t ban sustainability claims — it bans unbacked ones. In practice, the claims that get you into trouble share a pattern: a strong word, no specifics behind it.
- ✓Bare adjectives. “Eco”, “green”, “natural”, “sustainable”, “climate-neutral” used with nothing behind them.
- ✓Whole-product claims for partial facts. Calling a whole garment “sustainable” because the outer fabric is recycled, while the lining and trims aren’t.
- ✓Self-invented labels. A leaf icon or badge you designed yourself, presented as if it were third-party certified.
- ✓Future promises without a plan. “Carbon neutral by 2030” with no credible, checkable roadmap behind it.
- ✓Comparisons without a shared yardstick.“More sustainable than the leading brand” without a methodology both products could be measured against.
Notice what isn’t on that list: specific, checkable statements. “95% GOTS-certified organic cotton, certificate #12345” is not a vague claim — it’s a fact a regulator can verify in minutes. The whole Directive is really a nudge from adjectives towards specifics.
Don't be reassured by "transposition delay" headlines
Member States were supposed to have ECGT transposed into national law by 27 March 2026. EU transposition deadlines are missed fairly routinely across all kinds of directives, and it wouldn’t be unusual if a number of countries were still catching up here. If you see a headline suggesting ECGT itself is “delayed”, read it carefully: national transposition running late is a story about individual countries’ paperwork, not about the 27 September 2026 EU-wide application date moving. That date is fixed in the Directive text itself and doesn’t depend on any one country’s transposition being tidy by then.
The practical lesson for a small brand is the opposite of reassuring-sounding delay news: plan for 27 September regardless, and treat any claim that your own deadline has “slipped” with scepticism unless it comes from your own country’s official gazette.
What "evidence" needs to look like
ECGT doesn’t hand you a fixed checklist of acceptable proof — it requires claims to be backed by evidence that’s recognised and checkable. For a small brand, that translates into three practical moves:
The pattern: name the certifier, the percentage, the standard. Vague confidence is the thing being outlawed, not sustainability itself.
A Digital Product Passport isn't required — but it's the natural home for this
ECGT doesn’t mention Digital Product Passports and doesn’t require one. But the two rules solve related problems: ECGT asks you to be able to prove a claim, and a passport is a structured, public, QR-linked place to keep that proof next to the product it describes. If a customer or a national consumer authority ever challenges a “made from recycled materials” line on your packaging, a passport page naming the exact material share and certificate number answers the question in one scan, instead of an email thread.
Our ECGT guide walks through exactly how each passport section maps to common green claims, if you want the fuller version.
Your next two months, in order
- ✓Audit your own copy first. Read your website, packaging and marketplace listings the way a regulator would. Circle every environmental adjective.
- ✓For each circled word, ask "can I prove this?" If yes, add the specific evidence next to the claim. If no, either get the evidence or drop the word — a specific, modest claim beats a vague, unprovable one.
- ✓Check your labels and badges. If any icon on your packaging implies third-party certification, confirm it actually is one. If it’s something you designed, either get it certified or relabel it plainly as your own internal standard.
- ✓Put the evidence somewhere findable. A structured product page — ours or otherwise — beats evidence scattered across old supplier emails when someone actually asks.
- ✓Don't panic about future-performance claims. If you’ve made a “net zero by [year]” promise without a credible plan behind it, this is the year to either build the plan or soften the claim — not to add more like it.
None of this requires a consultant or a rebrand. It requires reading your own marketing with fresh eyes before a regulator, or a competitor, does it for you.