Green claims need evidence.

ECGT — the Empowering Consumers for the Green Transition Directive, formally Directive (EU) 2024/825 — amends EU consumer law. Generic environmental claims require relevant recognised excellent environmental performance, such as an applicable EU Ecolabel. Ordinary supporting documents alone do not meet that condition. Product neutrality claims based on carbon offsets are separately prohibited. See the Council's explanation of the restrictions.

It also changes pre-contract information about legal guarantees, durability and repair. A producer's free commercial durability guarantee covering the entire good for more than two years triggers specific harmonised-label duties. See the EU guarantee notice and GARAN label guidance.

The rules on unfair green claims have no general SME exemption. Small brands must check their claims too. National penalties depend on the breach; a 4% turnover figure is not an automatic fine for every case.

There are two separate EU files on greenwashing and people often confuse them:

ECGT and the wider rules against unfair commercial practices apply independently of that proposal. Review the adopted rules and your market's national guidance.

The Directive adds to the EU's blacklist of unfair commercial practices. Six specific practices are now banned:

1. 01
   Generic environmental claims without evidence

   Broad claims such as "eco-friendly" or "green" without relevant recognised excellent environmental performance. A broader term such as "sustainable" may also imply social characteristics that an environmental label alone cannot establish.
2. 02
   Claims about the whole product when only a part qualifies

   Marketing the entire product as sustainable when only one component or one stage of production meets the claim.
3. 03
   Sustainability labels not from a verified scheme

   Displaying a sustainability label that is neither based on a qualifying certification scheme nor established by public authorities.
4. 04
   Claims about future environmental performance without a clear plan

   "Carbon-neutral by 2030", "climate-positive 2040" without a substantiated, time-bound, third-party-verified roadmap.
5. 05
   Comparisons without comparable substantiation

   "More sustainable than competitors" without a like-for-like methodology that both products can be measured against.
6. 06
   Carbon-offset claims as the basis for neutrality marketing

   Claiming a product has a neutral, reduced or positive greenhouse-gas impact based on offsetting. Keeping offset receipts in a passport does not remove this prohibition.

A product page can make the information behind a specific claim easier to find. It is a place to explain your evidence, not a substitute for obtaining it or for required information on the same label, advert or selling interface as the claim.

Examples of information a brand could record, where it has the supporting documents:

• Claim: “Made from organic cotton”
  DPP evidence: The Materials section names the exact composition (e.g. "95% GOTS-certified organic cotton, 5% elastane") and the Certifications section names the certifying body and certificate number.
• Claim: “Designed for repair”
  DPP evidence: The Repair section names the spare parts available, the typical repair cost, and where to send the product for repair.
• Claim: “Recyclable”
  DPP evidence: The End-of-Life section explains which fraction is recyclable, in which collection stream, in which countries, with which limitations.
• Claim: “Made in the EU”
  DPP evidence: The Basics section names the country (and optionally the facility) of manufacture; the Materials section traces the country of origin for major components.
• Claim: “Low carbon”
  DPP evidence: Record a supported footprint figure, its scope, methodology and source in the relevant field or a custom section. A number or method name alone does not establish a valid comparative claim.

The passport doesn't make the underlying claim true — you still need an actual certificate, a real repair scheme or a credible carbon calculation. Product Passes does not verify those documents or certify legal compliance.