Certification scheme — ECGT certification scheme
A system for verifying compliance with public criteria, awarded by an independent certification body with periodic auditing. A canonical ECGT requirement for substantiating any sustainability label.
Context
A certification scheme is the system for verifying compliance with publicly defined criteria, awarded by a certification body independent of the trader, with periodic auditing. It is the mechanism behind any valid sustainability label under the ECGT.
Regulatory origin
A canonical concept of the ECGT Directive (EU) 2024/825, Annex I §4. It defines the minimum requirements a certification scheme must meet to be considered valid.
Requirements of a valid certification scheme
Governance independent of the certified trader.
Published, verifiable technical criteria.
Third-party auditor independent of the trader.
Periodic auditing with a minimum frequency.
Published compliance scale.
Timeline
ECGT Directive published
Defines the requirements of the certification scheme.
Transposition deadline
Member States transpose it.
Effective application
Invalid schemes no longer permit sustainability labels.
Applied case
A textile brand assesses whether the certification schemes underpinning its labels meet the ECGT requirements.
OEKO-TEX STANDARD 100: managed by OEKO-TEX Service GmbH (an independent body in Zurich) · public criteria at oeko-tex.com · audited by third-party accredited laboratories · valid.
GOTS: managed by Global Standard gemeinnuetzige GmbH (Stuttgart) · public criteria · audited by an Approved Certification Body · valid.
B Corp: managed by B Lab Company (Pennsylvania) · independent governance · audited by B Lab analysts · valid.
In-house "Eco-Friendly Brand" label: managed internally · self-certified · NOT valid · removed from the catalogue.
Common mistakes
A certification scheme requires verification by a THIRD party — not by a consultancy affiliated with the scheme owner.
Art. 2 (r) ECGT criterion (iv), in faithful paraphrase: it is carried out by a third party whose competence and independence from the scheme owner and the trader is based on international, Union or national standards. A consultancy paid by the scheme owner to perform audits is NOT a third party with respect to the owner — it is an interested party. Independence must be structural and based on international (ISO 17065), Union or national standards.
The four criteria are CUMULATIVE — a scheme may meet three and still not be valid.
Art. 2 (r) ECGT uses the list (i)(ii)(iii)(iv) with the conjunction "and" — all criteria must be met simultaneously. A scheme with (i) openness + (ii) participatory development + (iii) non-compliance procedures but without an independent third party for (iv) is NOT a valid certification scheme. The company cannot argue that "most are met".
ISO 17065 is an explicit reference in Recital 7 ECGT — but it is not the ONLY way to meet criterion (iv).
Recital 7 ECGT in fine, in faithful paraphrase: through the mechanisms provided for in Regulation (EC) No 765/2008 of the European Parliament and of the Council. Reg. 765/2008 on accreditation plus ISO 17065 are the typical routes for demonstrating the competence and independence of the third party. Other international standards (ISO 17021 for management systems, ISO 17020 for inspection) or EU/national equivalents (ENAC in Spain) may meet criterion (iv) where appropriate to the scheme.
The certification scheme does not exempt from greenwashing in parallel claims: it covers the scheme's requirements, not independent claims.
Recital 8 ECGT establishes a dual qualification. A brand displaying a valid sustainability label (e.g. GOTS) and also making unsubstantiated generic claims ("sustainable product") is subject both to the sustainability label regime (valid via GOTS) and to the environmental claim regime (prohibited under point 4a). The certification scheme validates the seal, not the parallel claims.
Self-declared marks or association seals without an independent third party are NOT certification schemes.
Self-declarations, seals from associations where the scheme owner is the very association of which the trader is a member, or schemes where monitoring is carried out by the scheme owner's staff are ineffective for criterion (iv). For textiles, seals such as "Made in Spain Sustainable" created by sector associations without an independent third-party structure fall outside Art. 2 (r) ECGT.
Frequently asked questions
What is a certification scheme?
A canonical concept of the ECGT Directive (EU 2024/825): a system for verifying compliance with publicly defined criteria, awarded by a certification body independent of the trader, with periodic auditing. Sector examples for textiles: OEKO-TEX, GOTS, GRS, EU Ecolabel, Fair Trade, Cradle-to-Cradle.
What requirements must a certification scheme meet under the ECGT?
In line with the Directive: (i) independent governance, (ii) published, verifiable technical criteria, (iii) third-party auditor independent of the trader, (iv) periodic auditing with a minimum frequency, (v) published compliance scale. Schemes lacking these requirements are NOT valid for substantiating sustainability labels.
How does a legitimate certification scheme differ from a self-declared one?
Legitimate: a certification body (OEKO-TEX Service GmbH, Global Standard gemeinnuetzige GmbH, Textile Exchange) independent of the trader, published criteria, third-party auditing, multi-stakeholder governance. Self-declared: the brand itself defines the criteria and self-certifies — prohibited under the ECGT as a sustainability label.
What is the difference between a private and a public certification scheme?
Private: managed by a non-governmental organisation (OEKO-TEX, GOTS, B Corp). Public: managed by a public authority (EU Ecolabel · Reg. 66/2010, ESRS verification by an auditor). Both are legitimate under the ECGT provided they meet the minimum requirements. The difference is the issuing authority, not the legal quality.
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
- ISO2012International standard
- European Parliament and Council · OJEU9 jul 2008Regulation in force

