Sustainability label — Sustainability label under the ECGT
A label, mark or seal that communicates the sustainability characteristics of a product to the consumer. Under the ECGT Directive (EU) 2024/825 it is only allowed if based on a verifiable certification scheme.
Context
A sustainability label is a label, mark or seal that communicates to the consumer the sustainability characteristics of a product. Allowed only when based on certification verifiable by an independent third party under ECGT Directive (EU) 2024/825.
Regulatory origin
Canonical concept under Annex I §4 of Directive 2005/29/EC as amended by the ECGT Directive (EU) 2024/825 published in OJEU L 6.3.2024.
Accepted sustainability labels
EU Ecolabel · official EU scheme under Reg. (EC) 66/2010.
OEKO-TEX STANDARD 100 · absence of harmful substances.
OEKO-TEX MADE IN GREEN · STANDARD 100 + STeP + BSCI/SA8000.
GOTS · Global Organic Textile Standard.
GRS / RCS / OCS · Textile Exchange.
Fair Trade · fair trade.
B Corp · company certification under B Lab Standards V2.2.
Timeline
ECGT Directive published
Amended Annex I §4 of Directive 2005/29.
Transposition deadline
Member States transpose.
Effective application
Self-declared sustainability labels become sanctionable.
Applied case
A textile brand audits its claims and labels ahead of the ECGT coming into application.
It detects use of an "own Eco-Friendly label" created internally without certification · unlawful post-ECGT.
It replaces it with OEKO-TEX STANDARD 100 (harmful substances) + GRS (recycled content) that it already had certified.
It communicates visually with the official OEKO-TEX logo + a verifiable certificate number at oeko-tex.com.
It updates packaging and website · a 12-month transition plan to use up stock bearing the old label.
Common mistakes
A sustainability label is not the same as a registered trademark: the TRADEMARK does not turn the label into a certification scheme.
Art. 2 (q) ECGT explicitly excludes "any mandatory label required under Union or national law" — but it does NOT exempt registered trademarks from the obligation to be based on a certification scheme. Recital 7 ECGT specifies that only certification marks (Art. 27 Dir. 2015/2436) established by a public authority or based on a certification scheme comply — ordinary trade marks owned by the textile brand that suggest sustainability without a certification scheme are caught.
Voluntary market standards (green bonds, ESG ratings) are NOT sustainability labels within the meaning of the ECGT.
Recital 7 ECGT in fine, faithfully paraphrased: voluntary market standards and voluntary public standards for green and sustainable bonds are not primarily aimed at retail investors and are subject to specific laws; for these reasons, such standards should not be considered sustainability labels for the purposes of this Directive.
The four certification-scheme conditions are cumulative — if one is missing, the label is not valid.
Art. 2 (r) ECGT literal uses a list (i)(ii)(iii)(iv) with a cumulative conjunction. A label where the monitoring is not done by an independent third party (e.g. internal self-certification or an audit by an affiliated consultancy) does not meet criterion (iv) and is therefore not a certification scheme — the linked label is prohibited under point 2a of Annex I.
The dual qualification: if the label suggests excellence, it is also an environmental claim.
Recital 8 ECGT, faithfully paraphrased: that sustainability label should also be considered to constitute an environmental claim. A label such as "Carbon Neutral Certified" displayed without a valid certification scheme simultaneously breaches: point 2a of Annex I (label without a scheme or authority), Art. 6 UCPD (misleading environmental claim), and point 4c of Annex I if it is based on offsetting (prohibited climate neutrality).
EU Ecolabel and EMAS are examples of lawful labels via route 2 (public authority) — they are not the only ones.
Recital 7 ECGT, faithfully paraphrased: examples of sustainability labels established by public authorities are the logos awarded where the requirements of Regulations (EC) No 1221/2009 (EMAS) or (EC) No 66/2010 (EU Ecolabel) are met. The word "examples" indicates a non-exhaustive list. Labels established by national or regional authorities (national type I schemes under EN ISO 14024 officially recognised) are also valid via route 2.
Frequently asked questions
What is a sustainability label under the ECGT?
Canonical concept under ECGT Directive (EU 2024/825) Annex I §4: a label, mark or seal that communicates to the consumer the sustainability characteristics of a product. E.g. EU Ecolabel, OEKO-TEX, GOTS, B Corp, Fair Trade. Allowed only when based on certification verifiable by an independent third party.
Which sustainability labels are accepted under the ECGT?
Under the ECGT Directive (EU) 2024/825 Annex I §4 (which amends Directive 2005/29/EC Annex I): only those based on a certification system — (i) certification granted by a recognised public or private body, (ii) verification by a third party independent of the trader, (iii) publicly available criteria, (iv) periodic auditing. Self-declared labels (created by the brand itself without external verification) are prohibited as an unfair commercial practice.
What is the difference between a sustainability label and a certification scheme?
The sustainability label is the SEAL visible to the consumer (e.g. the OEKO-TEX logo on the garment). The certification scheme is the SYSTEM behind the label (certifying body, criteria, audit, governance). A valid label always has a robust certification scheme behind it; a label without a scheme is unlawful under the ECGT.
What penalty is there for using false sustainability labels?
Under Directive 2005/29 + ECGT in transposition: fines up to EUR 1,000,000 + immediate withdrawal of the label from packaging/website/marketing + publication of the penalty. Additionally: possible criminal action for a corporate offence or false advertising under the Spanish Criminal Code (Art. 282).
Fuentes oficiales
- European Parliament and Council · OJEU OJ L of 6.3.202428 feb 2024Directive in force
- European Parliament and Council · OJEU28 feb 2024Directive in force
- European Parliament and Council · OJEU25 nov 2009 (Decisión 2014/350: 5 jun 2014)Regulation in force
