Empowering Consumers for the Green Transition (ECGT)
 

Sustainability has become a decisive factor in purchasing decisions, investment strategies, and brand perception. As consumers increasingly scrutinize environmental performance, businesses are investing heavily in communicating their sustainability commitments through product packaging, websites, e-commerce platforms, advertising campaigns, sustainability reports, and corporate communications.
 
However, growing demand for sustainable products has also led to an increase in greenwashing - the use of vague, misleading, or unsubstantiated environmental claims. Generic statements such as "green," "eco-friendly," or "carbon neutral" can be misleading when they are not backed by credible evidence.

To empower consumers to make informed, more sustainable purchasing decisions and hold businesses accountable for the sustainability claims they make, the European Union introduced the Empowering Consumers for the Green Transition (ECGT) Directive (EU) 2024/825. Designed to strengthen consumer protection and improve market transparency, the Directive marks a significant shift in sustainability communications, requiring companies to move beyond broad environmental messaging and support claims with verifiable, measurable, and transparent evidence.

For companies with robust data, independent verification, and credible consumer-facing labels, this creates an opportunity to turn substantiated climate action into trust, consumer preference, and market differentiation. For businesses operating in, communicating or selling products within the EU, the ECGT Directive or “EmpCo Directive”, as it is sometimes called, represents a new standard of accountability; one that places credibility, traceability, and substantiation at the heart of sustainability communications.

ECGT Directive and Its Implications for BusinesseS

Adopted to combat greenwashing and strengthen transparency across the European Union, the ECGT Directive will apply from 27 September 2026. The regulation requires organizations to ensure that sustainability commitments, achievements, and environmental benefits communicated to consumers are supported by verifiable data, measurable outcomes, and traceable records. As the Directive must be transposed into national law by each Member State, enforcement mechanisms and sanctions may differ across countries, creating variations in how the rules are implemented and enforced.

The Directive specifically targets misleading environmental communications, including: 

• Generic environmental claims that cannot be substantiated. 
• Sustainability commitments that lack clear evidence or implementation plans.
• Environmental benefit claims that do not rely on recognized methodologies.
• Offset-based claims that create the impression that a product has no environmental impact.

Generic Environmental Claims Require Evidence

One of the most significant changes concerns carbon neutrality claims. Organizations will no longer be able to market products as "carbon neutral" solely because they have purchased carbon credits or offsets. Such claims may be considered misleading under the ECGT Directive, particularly where offsets are outside the product's value chain. They may create the impression that a product has no environmental impact, even though its production generated greenhouse gas emissions.

Similarly, terms such as "green," "eco-friendly," "environmentally friendly," and "sustainable" can only be used when businesses clearly explain the specific environmental or social characteristics being claimed and provide supporting evidence through the same communication channel.

The Directive aims to help consumers make informed purchasing decisions while rewarding businesses that can demonstrate genuine sustainability performance. As a result, organizations will need robust processes to collect, validate, and maintain the evidence supporting sustainability commitments, achievements, and environmental claims. Independent verification, assurance, and traceable sustainability data can help strengthen the credibility of these claims, reduce compliance risks, and build greater confidence among consumers and stakeholders.
 

Stricter Rules for Sustainability Labels and Certifications

The ECGT Directive also introduces greater scrutiny of sustainability labels and certification schemes. Sustainability labels can only be used when they are either established by public authorities or based on a certification scheme. To qualify, the scheme must be a third-party verification scheme whose terms and requirements are publicly available and follow these four rules:

1. Based on a transparent certification system, open to all organizations able to comply under fair and non-discriminatory conditions.
2. Developed in consultation with experts and stakeholders.
3. Includes procedures to address non-compliance, including suspension or withdrawal of the label.
4. Compliance is monitored by an independent third party whose competence and impartiality are ensured in accordance with international, European, or national standards and procedures.

Organizations using sustainability labels or certification schemes will need to ensure that the underlying criteria, governance, and verification processes meet these requirements. Examples include:

• EU Ecolabel
• EN ISO 14024 Type I Environmental Labelling Schemes
• Other independently verified certification programmes

Meeting these requirements may require closer collaboration between sustainability, legal, product, compliance, and marketing teams to ensure labels are supported by transparent processes, robust evidence, and accurate communications.

Existing Products Will Also Be Affected

The Directive does not apply only to new products entering the market. Organizations should also assess environmental, social, and sustainability claims made on existing products, packaging, labels, and related marketing communications that remain available to consumers. While recent guidance from the European Commission acknowledges the practical challenges associated with existing stock, businesses are still expected to take steps towards compliance and should not assume that legacy claims are automatically exempt from scrutiny.

Where existing claims do not meet the new requirements, organizations may need to implement corrective actions such as:

• Updating packaging and product information.
• Applying corrective labels or stickers where appropriate.
• Providing additional information at the point of sale.
• Revising website content, digital communications, and marketing materials.
• Reviewing environmental claims used across customer-facing channels.

Taking early action can help organizations reduce compliance risks, prioritize remediation efforts, and manage the transition to the new requirements more effectively ahead of the Directive's application date.

Building Confidence in Sustainability Communications

As expectations around environmental claims become more rigorous, credibility is emerging as a critical differentiator. Organizations are increasingly expected to demonstrate that sustainability-related statements are supported by robust evidence, transparent methodologies, and verifiable data.

In this evolving landscape, independent verification can play an important role in helping businesses navigate complexity with greater confidence. Bringing together expertise in testing, inspection, certification, verification, and assurance, Bureau Veritas has extensive experience supporting organizations as sustainability requirements become more demanding and regulatory expectations continue to evolve.

For businesses, this means assurance can become more than a technical exercise. Verified product carbon data can be translated into clearer, more credible market-facing communication through a recognised carbon footprint label, helping companies respond to regulatory expectations while strengthening trust with consumers, customers, procurement teams and other stakeholders.

Moving from broad environmental messaging to evidence-based communication requires a clear understanding of claim substantiation, data quality, traceability, and governance. Organizations that take a structured approach to validating sustainability claims are better positioned to demonstrate transparency, reduce compliance risks, and strengthen stakeholder confidence.

Preparing for Greater Scrutiny of Environmental Claims

As regulatory oversight of environmental communications increases across Europe, organizations can benefit from taking a proactive approach by:

• Reviewing environmental and sustainability claims across products, packaging, websites, and marketing materials.
• Ensuring claims are supported by reliable, traceable, and verifiable evidence.
• Evaluating the relevance and robustness of certification schemes and environmental labels including whether they are based on transparent scheme requirements, independent third-party verification and clear procedures for non-compliance.
• Where product carbon claims are central to consumer communication, considering whether a recognised product carbon footprint label could provide a clearer, more robust way to communicate verified progress.
• Building internal awareness of emerging requirements and responsibilities.
  Strengthening collaboration across sustainability, legal, compliance, product, and marketing teams.
• Seeking independent review of sustainability claims to enhance credibility and transparency.
   

From Compliance Requirement to Trust Advantage

The ECGT Directive reflects a broader evolution in sustainability communication, where credibility matters as much as commitment. Organizations are being challenged to move beyond aspirational messaging and demonstrate measurable evidence behind the claims they make.

Those that embed transparency and verification into their sustainability communications will be better positioned to build trust with consumers, regulators, investors, and business partners. In a market where stakeholders increasingly scrutinize environmental claims, credibility has the potential to become a lasting competitive advantage.

This shift is not simply about meeting regulatory requirements. It is about creating confidence in the sustainability story an organization chooses to tell.

Environmental claims are entering a new era of accountability.

Join our upcoming webinar with Carbon Trust, Countdown to the ECGT Directive: Are Your Sustainability Communications Ready? to explore the implications of the ECGT Directive and learn how organizations can strengthen the credibility, transparency, and compliance of their sustainability communications.