Recognised excellent environmental performance — Recognised excellent environmental performance ECGT
A canonical condition of the ECGT Directive (EU) 2024/825 for using excellence environmental claims. It requires a recognised seal (EU Ecolabel) or a validated comparative study proving top-tier performance.
Context
The concept of "recognised excellent environmental performance" is the canonical condition of the ECGT Directive (EU) 2024/825 for using commercial claims of environmental excellence. Environmental leadership can only be claimed if it is backed by a recognised seal (e.g. EU Ecolabel) or by a validated comparative study proving superior performance relative to the market average.
Regulatory origin
A canonical amendment to Annex I of Directive 2005/29/EC on unfair commercial practices, introduced by the ECGT Directive (EU) 2024/825 published in OJEU L 6.3.2024. It applies as a commercial practice automatically deemed unfair in all circumstances.
Which claims require backing
Excellence claims such as "the most sustainable", "sustainability leader", "superior environmental performance".
Implicit comparison claims ("among the most sustainable in the sector").
Absolute claims without qualification ("100 per cent sustainable", "carbon neutral").
How an excellence claim is substantiated
EU Ecolabel seal or an equivalent recognised by the European Commission.
Published comparative LCA study using the EU PEF methodology or ISO 14040/14044.
Top-tier sector certification (Cradle-to-Cradle Platinum, BREEAM Outstanding, etc.).
Published comparative study with a replicable methodology and data accessible for verification.
Difference from a generic sustainability label
A generic sustainability label (e.g. OEKO-TEX STANDARD 100) verifies compliance with minimums. The concept of "recognised excellent environmental performance" verifies a top-tier position (better than the rest of the market). A brand with OEKO-TEX may communicate it, but it may NOT claim "the most sustainable" without a comparative study or EU Ecolabel.
Timeline
ECGT Directive published
Directive (EU) 2024/825 published in OJEU L 6.3.2024.
Transposition deadline
Member States transpose the ECGT into national law.
Effective application
The transposed national measures apply in full.
Applied case
A textile brand analyses three pre-ECGT claims in its catalogue and reformulates them to meet the recognised excellence requirement.
"Energy-efficient care labelling" with no comparative basis. Post-ECGT rating: unlawful.
"Labelling with washing instructions at 30 degrees that reduce washing energy consumption by approximately 35 per cent compared with washing at 60 degrees (reference: Rüdenauer et al., Eco-Efficiency Analysis of Washing Machines, Öko-Institut, 2004)". A verifiable comparative citation with a public methodology.
"The most sustainable textile brand in Spain" with no comparative study. Post-ECGT rating: unlawful.
Replaced by a description of specific verifiable achievements: "Certified B Corp with a score of 145 points (BIA V1)". No comparative excellence claim.
Common mistakes
Recognised excellent environmental performance is NOT equivalent to any private environmental certification — it is limited to three specific legal routes.
Art. 2 (s) ECGT verbatim limits it to (1) Reg. (EC) No 66/2010 EU Ecolabel; (2) EN ISO 14024 type I ecolabelling schemes officially recognised in Member States; (3) top environmental performance under other applicable Union law (e.g. class A Reg. 2017/1369). Private schemes such as GOTS, OEKO-TEX, GRS, Bluesign are valid certification schemes for sustainability labels but are NOT automatically recognised excellent environmental performance — they may be if Union law explicitly recognises them, which is not generally the case.
The exception must be RELEVANT to the specific claim — it does not exempt generic claims about characteristics not covered.
Recital 10 ECGT in fine verbatim: "The recognised excellent environmental performance in question should be relevant to the entire claim." The recital example is direct: complying with the EU Ecolabel for textiles (which covers chemical substances, efficiency, quality) does NOT allow a "biodegradable" claim because Decision 2014/350 has no biodegradability requirements. The company must verify that the technical coverage of the chosen route covers exactly the content of the claim.
The claims "conscious", "sustainable", "responsible" mix environmental and social dimensions — they cannot be based solely on recognised excellent environmental performance.
Recital 10 ECGT in fine, in faithful paraphrase: a trader should not make a generic environmental claim such as "conscious", "sustainable" or "responsible" based solely on recognised excellent environmental performance, because such claims refer to characteristics other than environmental ones, such as social ones. To support those claims, the brand must combine recognised excellent environmental performance + substantiation of the social dimension.
Class A under Reg. (EU) 2017/1369 (energy labelling) is an explicit example of top performance under other Union law — but only class A, not class B.
Recital 10 ECGT verbatim cites "class A in accordance with Regulation (EU) 2017/1369". The energy labelling regime has classes A (top) through G (bottom). Only class A constitutes enabling top environmental performance. Classes B-G do not qualify as recognised excellent environmental performance under Art. 2 (s) ECGT via route 3.
Compliance must be CERTIFIED or legally documented — the trader's internal assertion is not enough.
Recital 10 ECGT verbatim uses "compliance with" as the criterion, which requires formal evidence of compliance. For Reg. 66/2010 EU Ecolabel: an official licence granted by a competent body. For EN ISO 14024 type I: a licence from the officially recognised scheme. For Reg. 2017/1369: documented class A certification. Self-declarations without an official process do NOT substantiate recognised excellent environmental performance.
Frequently asked questions
What does recognised excellent environmental performance mean?
A canonical concept of the ECGT Directive (EU 2024/825): a condition for using environmental excellence claims. This type of claim can only be used if it is based on recognised top-tier standards (e.g. EU Ecolabel) or validated comparative studies proving superior performance relative to the market average.
Which claims require recognised excellent environmental performance?
Excellence claims such as "the most sustainable", "sustainability leader", "superior environmental performance". These claims can ONLY be used if the company has an EU Ecolabel or another seal/study that objectively proves the top-tier position. Without this evidence, they are prohibited generic environmental claims.
How is an environmental excellence claim substantiated?
By means of: (i) an EU Ecolabel seal or a recognised equivalent, (ii) published comparative LCA studies using the PEF/ISO 14040 methodology, (iii) a top-tier sector certification (Cradle-to-Cradle Platinum, etc.). The comparative study must be publicly available for verification.
What is the difference between recognised excellent and a generic sustainability label?
A generic sustainability label (e.g. OEKO-TEX STANDARD 100) verifies compliance with minimums. Recognised excellent verifies a TOP-TIER position (better than the rest of the market). A brand with OEKO-TEX may communicate it; but it may NOT claim "the most sustainable" without a comparative study or EU Ecolabel.
Fuentes oficiales
- European Parliament and Council · OJEU OJ L of 6.3.202428 feb 2024Directive in force
- European Parliament and Council · OJEU25 nov 2009Standard in force
- European Parliament and Council · OJEU4 jul 2017Standard in force
- ISO2018International standard
