EU Regulation Guide

ECGT: the EU’s new no-greenwashing law, in force from 27 September 2026

From 27 September 2026, every “eco-friendly”, “sustainable” or “climate-neutral” claim on a product sold in the EU needs proof a regulator can check. Here’s what the ECGT Directive (EU 2024/825) requires, what it prohibits, and how a Digital Product Passport gives you the evidence trail.

ECGT applies in approximately 4 months — start substantiating your claims now

What is ECGT?

ECGT — the Empowering Consumers for the Green Transition Directive, formally Directive (EU) 2024/825 — is an amendment to the EU Unfair Commercial Practices Directive that targets greenwashing head-on. It bans traders from using generic environmental claims (“eco-friendly”, “green”, “climate-neutral”, “sustainable”, “natural”) unless they can substantiate those claims with recognised, verifiable evidence.

ECGT also requires every product carrying a commercial guarantee of durability or repairability to make that information accessible to the consumer at the point of sale — a logical companion to the Digital Product Passport.

Crucially, ECGT applies to every business trading with EU consumers, with no SME exemption. A micro-brand in Helsinki making 50 textile pieces a month is subject to the same substantiation rule as a multinational. The penalties are designed to bite: fines for widespread breaches reach at least 4% of a trader's annual turnover in the relevant Member State.

ECGT vs the Green Claims Directive

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

ECGT (Dir. 2024/825)
In force. Applies 27 Sep 2026.

Bans unsubstantiated green claims. Requires that environmental claims be backed by evidence consumers and regulators can check. This is the law.

Green Claims Directive (Proposed COM(2023) 166)
In legal limbo as of 2026.

Would require pre-approval of green claims by a verified third party. Commission announced intent to withdraw in June 2025 but has not formally withdrawn. Status is unclear — do not rely on it.

With the Green Claims Directive paused, ECGT carries the entire greenwashing-backstop load from 27 September 2026. If you only prepare for one of these, prepare for ECGT.

What ECGT prohibits, in practice

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
    Words like "eco", "eco-friendly", "green", "natural", "climate-neutral", "sustainable", "biodegradable" used without recognised proof of excellent environmental performance.
  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
    Self-invented eco-labels, or third-party labels without certification by recognised public or accredited private schemes.
  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 is climate-neutral primarily because emissions are offset (rather than reduced) is now misleading by default.

ECGT timeline — key dates

26 March 2024ECGT enters into force

Directive (EU) 2024/825 published. Member States have until 27 March 2026 to transpose it into national law.

27 March 2026Member State transposition deadline

All 27 EU Member States must have published their national implementing legislation.

27 September 2026ECGT applies EU-wide

Every product placed on the EU market must comply. Generic green claims without evidence are banned. National consumer authorities begin enforcement.

From late 2026Enforcement and case law begin

First national enforcement actions expected; first cross-border cases via the CPC network. Penalties for widespread breaches reach 4% of turnover in the relevant Member State.

How a Digital Product Passport substantiates your green claims

ECGT enforcement is documentary. When a national consumer authority (or a customer, or a competitor) challenges a green claim, you have to show evidence. A Digital Product Passport is exactly that — structured, machine-readable, attached to the product itself via QR code, accessible at any time without a login.

Every productpasses.com passport gives ECGT-style evidence by default:

  • 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: Each category template includes a place for the carbon-footprint figure (kg CO₂e per unit) and the calculation methodology used. ECGT requires comparable methodology — just naming it puts you ahead of competitors who don't.

The passport doesn't make the underlying claim true — you still need an actual GOTS certificate, a real repair scheme, a credible carbon calculation. What it does is make the evidence trail visible and structured, so the substantiation review takes minutes instead of weeks.

Frequently asked questions

What is ECGT?
ECGT is the Empowering Consumers for the Green Transition Directive — Directive (EU) 2024/825. It amends the Unfair Commercial Practices Directive to ban generic green claims (like 'eco-friendly', 'green', 'climate-neutral') unless the trader can substantiate them with recognised evidence. It applies in all 27 EU Member States from 27 September 2026.
When does ECGT come into effect?
ECGT entered into force on 26 March 2024. Member States must transpose it into national law by 27 March 2026, and the rules apply uniformly across the EU from 27 September 2026. There is no transition period after that date — every product on sale must comply.
What does ECGT prohibit?
Generic environmental claims without verified evidence ('eco', 'green', 'natural', 'sustainable', 'climate-neutral'); claims about future environmental performance without a clear plan; sustainability labels not based on a certification scheme or set by public authorities; comparing your product's environmental performance to other products without comparable substantiation. Selective disclosure — highlighting one good feature while hiding bad ones — is also prohibited.
Does ECGT apply to small businesses?
Yes. ECGT applies to every business trading with EU consumers, regardless of size. There is no SME exemption. A linen-shirt brand making 50 garments a month is subject to the same substantiation rule as a multinational fashion house.
What are the penalties for ECGT non-compliance?
Penalties are set by each Member State, but the Directive requires them to be 'effective, proportionate, and dissuasive'. For widespread or cross-border infringements, fines must reach at least 4% of the trader's annual turnover in the relevant Member State. National consumer authorities can also order products to be withdrawn or claims to be retracted.
How does a Digital Product Passport help with ECGT?
A Digital Product Passport is structured, machine-readable evidence — materials, certifications, repairability, end-of-life information — attached to the product itself via a QR code. When a regulator (or a curious consumer) checks the basis for a 'sustainable' or 'circular' claim, the DPP is the documentation they look at. A passport that names specific certifications and quantified facts is far stronger evidence than marketing copy alone.
Is ECGT the same as the Green Claims Directive?
No. The Green Claims Directive (proposed COM(2023) 166) is a separate, more detailed law that would require pre-approval of environmental claims. As of 2026, that proposal is in legal limbo — the Commission announced intent to withdraw it in June 2025 but has not formally withdrawn. ECGT (2024/825) is in force and applies on 27 September 2026 regardless. ECGT is the practical backstop against greenwashing today.

Substantiate your green claims before 27 September 2026

productpasses.com gives every product an ECGT-ready evidence trail — structured materials, certifications, repair and end-of-life data on a scannable QR-linked page. Free for up to 5 products.

Start free →
See also: ESPR explained → · what a DPP is →