Empowering Consumers for the Green Transition Directive

A textile brand with a B2C market presence audits its catalogue and marketing communications ahead of the ECGT coming into application (27 Mar 2027).

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  Audit of claims across the website + physical store + social media · identifies 47 environmental claims without substance.

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  For 30 claims · substantiable with data: it adds a citation of certification (GOTS, OEKO-TEX, RCS) or an LCA study with PEFCR methodology.

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  For 17 claims · not substantiable: it removes them or reformulates them as a factual description without an environmental claim.

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  It implements an internal pre-publication review process: any new environmental claim requires legal + technical validation before it goes out.

Common mistakes

• The ECGT prohibits generic "green" or "eco-friendly" claims in all circumstances, not just when the consumer is confused.

  Annex I of Directive 2005/29/EC, as amended by the Annex to Directive 2024/825, lists the practices as "unfair in all circumstances" (heading of Annex I UCPD). The new point 4a, faithfully paraphrased: making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. Recital 9 includes "green", "eco-friendly", "environmentally friendly", "nature's friend", "ecological", "climate friendly", "biodegradable", "biobased" or other similar formulations among the prohibited examples. No case-by-case analysis or proof of confusion is required: merely making the claim without demonstrable recognised excellent environmental performance is automatically unfair.

• The ECGT is not the future Green Claims Directive: there is no ex ante verification by an independent body here for every claim.

  The ECGT (Dir. 2024/825) prohibits categories of generic and offsetting claims, requires claims about future performance to be supported by a plan verifiable by an independent third-party expert (Art. 6(2)(d) UCPD as amended by Art. 1 point (2)(b) ECGT) and reinforces pre-contractual information. But it does not impose a general regime of prior verification for every specific environmental claim — that piece is provided for in the proposal for a Green Claims Directive (COM(2023) 166 final) in the legislative process at the close of this term. Confusing the two leads to underestimating the immediate force of the ECGT (binding in absolute circumstances via the amended Annex I UCPD) or to overestimating prior-verification obligations.

• The "carbon neutral" claim with offsetting is prohibited even if the offsetting is real and certified.

  The new point 4c of Annex I UCPD, faithfully paraphrased: claiming, on the basis of the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of GHG emissions. Recital 12 lists, by way of example, the affected formulations: "climate neutral", "CO2 neutral certified", "carbon positive", "climate net zero", "climate compensated", "reduced climate impact" and "limited CO2 footprint". Recital 12 in fine allows these claims only when they are based on the actual lifecycle impact of the product and not on offsetting of GHG emissions outside the product's value chain. The quality or certification of the carbon credits does not save the claim when it is made about the product.

• Presenting a feature that is mandatory by law as a differentiator is an absolute unfair practice.

  The new point 10a of Annex I UCPD, faithfully paraphrased: presenting as a distinctive feature of the trader's offer requirements imposed by law on all products in the relevant category on the Union market. Recital 15 specifies the case and clarifies that the prohibition does not cover practices that promote compliance with legal requirements that apply only to some products but not to competitors in the same segment (for example, non-EU products not subject to the requirement). For textiles, this particularly affects claims that highlight as one's own advantage compliance with Reg. (EU) 2023/1115 EUDR, Reg. (EU) 2024/3015 on forced-labour products or future ESPR requirements when all competitors are subject to them.

• The ECGT is not just anti-greenwashing: the second pillar reforms pre-contractual information on durability and reparability.

  Art. 2 ECGT amends six aspects of Dir. 2011/83/EU: new definitions (14a-14e) including "reparability score" (Art. 2 point (1)) and it inserts Art. 22a, faithfully paraphrased: a harmonised notice shall be used for the information under Art. 5(1)(e) and Art. 6(1)(l), and a harmonised label shall be used for the information under Art. 5(1)(ea) and Art. 6(1)(la); by 27 September 2025 the Commission shall specify, by means of implementing acts, the design and content of the harmonised notice. The trader is required, before the consumer is bound by the contract, to inform about the commercial guarantee of durability where the producer offers it for more than two years covering the entire good (amended Art. 5(1)(ea) and 6(1)(la)), about the reparability score where established at Union level (added Art. 5(1)(i) and 6(1)(u)) and about the minimum period of software updates (added Art. 5(1)(ed) and 6(1)(lc)).

Frequently asked questions