In this article, learn about:
- Why the EU's new greenwashing rules apply to any supplier selling products to consumers in the EU
- Which environmental claims are banned from 27 September 2026 and which remain permissible
- What the new rules mean for sustainability labels and third-party verification
- What non-compliance costs and where enforcement sits
What the ECGT Is and Why September Is the Deadline
The Empowering Consumers for the Green Transition Directive (ECGT, EU 2024/825) applies from 27 September 2026. It fundamentally changes what environmental and sustainability claims can be made on products sold to consumers in the EU, covering packaging, product listings, advertising, and in-store materials.
The directive does not require suppliers to become more sustainable. It requires them to be specific and verifiable about the sustainability claims they already make. Vague or unsubstantiated claims, including many that are currently standard practice across retail packaging, are banned from that date.
There is no transition period. The deadline is the deadline.
"From 27 September 2026, generic environmental claims without specific, verifiable substantiation are prohibited across all EU member states."
The rules apply to any business selling products to consumers in the EU, regardless of where that business is based. If your product is on a shelf or a product listing targeting EU consumers, the ECGT applies to the claims on it.
What Gets Banned From 27 September 2026
The ECGT introduces 12 newly prohibited commercial practices targeting misleading environmental claims. The core categories of banned claims are:
| Banned claim type | Examples |
|---|---|
| Generic environmental claims without substantiation | "Eco-friendly," "green," "natural," "sustainable," "kind to the planet," "conscious" |
| Unsubstantiated biodegradability claims | "Biodegradable" without specifying conditions, timeframe, or certification |
| Self-certified sustainability labels | Any label created without independent third-party verification and regular monitoring |
| Offset-based climate neutrality claims | "Carbon neutral," "climate neutral," or "net zero" claims based on purchasing carbon offsets rather than actual emission reductions |
Specific, verifiable claims remain permissible. The distinction the ECGT draws is between claims that can be independently substantiated and claims that cannot. "Made from 30% recycled plastic, certified by the Global Recycled Standard" is permissible. "Made with recycled materials" without further detail is not.
What the Rules Mean for Sustainability Labels
The ECGT introduces a significant restriction on sustainability labels specifically. From 27 September 2026, a sustainability label can only be used on products sold in the EU if it meets one of 2 criteria:
- It is established by a public authority
- It is based on a certification scheme that complies with the ECGT's requirements, with independent third-party verification, regular monitoring, and a rigorous stakeholder development process
Self-created labels, where a brand or supplier develops and applies its own sustainability mark without external verification, are no longer permitted. This affects a significant number of packaging and product labels currently in circulation across retail categories.
Labels that are already based on recognised third-party schemes are not affected. Certifications such as the EU Ecolabel, Fairtrade, Rainforest Alliance, Global Organic Textile Standard (GOTS), and Global Recycled Standard (GRS) remain compliant, provided they are referenced specifically and accurately.
Who the Rules Apply To
The ECGT applies to any trader selling to consumers in the EU, regardless of where the business is headquartered. The scope covers packaging claims, product listings on retailer websites, in-store point-of-sale materials, and any advertising directed at EU consumers.
Suppliers operating across multiple markets need to ensure that claims on products entering EU retail channels meet the ECGT standard. A claim acceptable in one market may be non-compliant under the directive if the same product is stocked in the EU.
What Non-Compliance Costs
Enforcement sits with national authorities in each EU member state. The directive sets fines of up to 4% of annual turnover in the affected member states for widespread infringements, or a minimum of €2 million where turnover cannot be ascertained.
Beyond financial penalties, the reputational consequences of a greenwashing enforcement action are harder to quantify, particularly in markets where sustainability credentials carry commercial weight. EU retailers operating under their own sustainability reporting obligations are increasingly scrutinising the claims their suppliers make at shelf. An enforcement action against a supplier's claims creates complications for the retailer's own reporting.
What to Review Before 27 September 2026
Six weeks is not a long window for a packaging or labelling change. The practical priority is an audit of existing claims across every product going into EU retail channels.
The most common non-compliant claims currently in circulation are generic terms on outer packaging and product listings: variations of "eco-friendly," "sustainable," "green," or "natural" used without a specific, verifiable reference. These need to either be removed, replaced with specific claims that can be substantiated, or backed by an independently verified certification that is named and referenced.
For suppliers whose EU retail listings are managed through retailer portals or through an EDI-connected trading relationship, claim changes may also need to flow through product data updates. SPS Commerce supports suppliers in managing product and compliance data across EU and UK retail trading relationships, with connections to major retailers already built into a managed network of more than 300,000 trading partners. When specification or data requirements change across multiple accounts, central management avoids the same update becoming a separate project for each retailer.
The European Commission's ECGT FAQ is the authoritative source for current guidance on specific claim types and what substantiation each requires.