ECGT: new EU rules for sustainability claims

To better protect consumers and tackle greenwashing decisively, the European Commission introduced the Directive on Empowering Consumers for the Green Transition (ECGT), also known as EmpCo, nearly three years ago (27 March 2024). This directive supplements the existing Unfair Commercial Practices Directive (2005/29/EC), which has protected consumers against misleading communication since 2005 by imposing fines of up to at least 4% of turnover (or €2 million). 

Since 27 September 2026, the Dutch implementation act for the European Directive on Empowering Consumers for the Green Transition has been in force. The stricter rules therefore now apply to organisations that engage in consumer-facing communication. Organisations should review existing and new sustainability claims, labels and communications against the new requirements. Rather than being just a compliance exercise, it presents a valuable opportunity for leading organisations to highlight and differentiate their achievements.

What exactly does the ECGT entail?

The ECGT introduces new, stricter rules for sustainability communication:

• No more vague environmental claims: Terms such as “green” and “eco” are only permitted if they are demonstrably substantiated.
• (Audio)visual communication also counts: Colours, icons, speech and nature imagery may be regarded as misleading claims.
• Climate neutrality requires more than compensation: Such claims must be based on lifecycle assessments. Claims that rely solely on CO₂ compensation are prohibited.
• Strict requirements for sustainability labels and certification schemes: Only transparent, independent and verified labels are permitted.
• Mandatory product information: Companies must provide insight into lifespan, repairability, updates and environmental impact.
• Ban on planned obsolescence: Manufacturers may no longer deliberately shorten the lifespan of products, for example through software updates that slow down older devices or restrict functionality.
• Expansion of the blacklist: Among other things, misleading social claims will now also fall under unfair commercial practices.

In short, sustainability claims must from now on be specific, concrete and demonstrable. Below we share a number of examples:

What does this mean for you?

The ECGT requires more than minor adjustments: organisations must structurally professionalise their sustainability communication. This involves stricter substantiation and proof, reorganisation of marketing claims, greater transparency about product sustainability, stricter enforcement, and structural adjustments in governance and the supply chain.

Strengthened substantiation and burden of proof

For every sustainability claim, there must be demonstrable evidence, based on transparent, verifiable data. Each claim must be traceable to underlying substantiation, such as policies, measurement methods, reports or certifications.

Stricter requirements for labels

All labels and certifications must meet higher standards of reliability and transparency, and follow a demonstrable, audited standard.

Adjustment of marketing & product communication

Marketing departments must revise their sustainability language. Commonly used ‘green’ terms must be avoided. Texts, packaging, websites and advertisements must be rewritten. Visual claims, such as icons and badges, must also be adjusted.

Operational changes in product information

The directive affects product development, the supply chain and after sales. Organisations must be transparent about lifespan, repairability and environmental impact across the full life cycle. This may require collaboration with new suppliers and re conducting a Life Cycle Assessment.

Higher risks of enforcement and sanctions

National regulators, such as the Netherlands Authority for Consumers and Markets (ACM), already enforce the Unfair Commercial Practices Directive and, thanks to the ECGT, are given a stronger basis to act against greenwashing. This increases the risk of fines, corrective measures, public naming & shaming and civil claims.

Need for internal governance & control processes

With the ECGT, sustainability communication becomes a governance issue. Sustainability claims increasingly require cross-functional governance involving sustainability, legal, compliance, product, procurement and marketing teams. Organisations that embed claim governance into existing risk and decision-making processes are generally better positioned to respond to evolving regulatory expectations.

Consider links to other sustainability directives

The ECGT is not a pure standalone directive but supplements and complements existing EU sustainability regulatory frameworks. Although the proposed Green Claims Directive is currently on hold, organisations can already benefit from strengthening the governance, evidence base and substantiation of sustainability claims. Many of the capabilities needed under a future Green Claims framework are also relevant under the ECGT, but also support other regulatory frameworks such as the CSRD.

What should you do?

The directive has been in effect since 27 September 2026. Therefore, it is crucial to get your house in order. Below are focus areas to establish a risk-based approach to sustainability communication and embed the processes that strengthen the credibility of sustainability claims:

1. Carry out a full review of all sustainability claims
   Start by making an inventory of all existing claims, visuals, certifications and labels. Consider all possible places where claims and communication may occur, from websites to packaging and from social media to annual reports. Assess the claims against the updated criteria.
2. Ensure hard, verifiable substantiation
   To substantiate sustainability information, companies often need structural improvements, such as:
   1. better data collection from suppliers,
   2. documented measurement methods,
   3. contractual agreements on transparency in the value chain,
   4. internal controls (audit trails) for data and claims.
3. Put governance in place for sustainability claims
   An organisation that makes claims needs claim governance. This means having internal procedures for reviewing claims, such as clear processes and involving the right departments, including marketing, legal, product and sustainability.
4.  Train employees
   Non compliance often starts small: one ill considered sentence or a hasty addition can easily slip in. Train teams on what is and is not permitted, and ensure everyone uses the same definitions and standards.

Sustainability certificates

The ECGT puts an end to the use of unsubstantiated sustainability labels. Only independent, transparent and verifiable certifications will remain permitted. This forces organisations to critically review their certification landscape.

For many companies, this actually presents an opportunity to opt for robust, internationally recognised standards and differentiate your organization from others. These standards can be set by governmental institutions but also by private organisations. For example, a certification such as B Corp fits this approach: stringent, scientifically backed and externally verified.

How we can help

We support organisations in professionally and future‑proof setting up their sustainability communication, including through:

• Claim check & risk scan
• Setting up claim governance & internal guidelines
• Sustainability certifications such as B Corp
• Data‑driven substantiation of claims
• Training & workshops for teams and suppliers

On 24 November we organise a masterclass Credible sustainability communication in Dutch. You will learn how to formulate sustainability claims clearly, substantiate them convincingly and communicate them responsibly in a time of stricter requirements. We cover current regulations, practical examples, concrete exercises and governance, roles and responsibilities. Participants receive checklists and sample materials and can bring their own claims or communication expressions.

Are you interested in an English masterclass? Please let us know. 
 

Conclusion: those who prepare now will reap the benefits later

Companies that take action now will benefit from lower risks, greater credibility and a competitive edge:

• Avoid greenwashing risks by timely revising claims, visuals and certifications.
• Limit legal and reputational damage by putting substantiation and data quality in order.
• Build sustainable brand trust with transparent, verifiable and honest communication.
• Be ready for stricter enforcement by structurally improving processes and governance.
• Create competitive advantage by investing in demonstrable sustainability claims.

The ECGT changes the playing field. Impact House by Grant Thornton is ready to guide you through this process, from strategic choices to practical implementation. Would you like to know more or discuss these insights further? Get in touch with us.

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