ECGT Regulation: A Step by Step Compliance Guide for Product Companies
Everything product companies need to know, plus a simple step by step plan to get compliant
When a product company hears “ECGT”, the first worry is usually the same one: does this mean the website and packaging have to change?
Yes, often.
ECGT is the EU’s Empowering Consumers for the Green Transition Directive, and it is mainly about stopping misleading environmental marketing, tightening the rules around sustainability labels, and improving consumer information about products. (Source: European Commission, 2024). (Source: Directive (EU) 2024/825, 2024).
This guide is written for companies that sell physical products and want a clear plan.
What is ECGT regulation?
ECGT is Directive (EU) 2024/825. It amends existing EU consumer laws to better protect consumers from unfair practices linked to sustainability claims and to improve information related to durability and repairability. (Source: Directive (EU) 2024/825, 2024). (Source: European Commission, 2024).
In plain terms, ECGT affects:
What can be claimed about a product’s environmental performance
How sustainability labels are used
How certain product information is presented to consumers
How claims are compared across products in marketing
ECGT matters because it turns common green marketing habits into compliance risks.
Who ECGT applies to
ECGT applies to business to consumer marketing that reaches EU consumers.
That includes product companies that:
Sell directly to EU consumers online
Sell through EU retailers or marketplaces
Market products to EU consumers, even if sales happen elsewhere
Use EU languages, EU targeted ads, EU shipping pages, or EU specific campaigns
It is not only for EU headquartered companies. The practical trigger is communicating to EU consumers. (Source: B Lab, 2025).
When ECGT comes in
The key dates are:
27 March 2026: EU Member States must transpose ECGT into national law. (Source: European Commission, 2024). (Source: Hogan Lovells, 2025).
27 September 2026: the rules apply across the EU. (Source: European Commission, 2024). (Source: Hogan Lovells, 2025).
National enforcement and penalties will be handled by Member State authorities, so details can vary by country. (Source: European Commission, 2024).
What ECGT changes for product companies
Most teams feel this in marketing first, but it touches product, legal, ESG, ecommerce, brand, and customer support.
1) Environmental claims get much harder to “wing”
ECGT adds more practices to the list of what is considered misleading, including:
Generic environmental claims such as “eco friendly”, “green”, “climate friendly”, when the company cannot show recognised excellent environmental performance relevant to the claim. (Source: Reuters, 2024). (Source: DWF, 2026).
Product level “climate neutral” type claims based on offsetting being treated as prohibited in this regime, pushing companies away from using offsets as a marketing shortcut. (Source: European Parliament, 2024). (Source: Reuters, 2024).
Claims about an entire product or business when the evidence only covers one part. (Source: DWF, 2026).
Comparisons and comparative claims needing clear methods and clarity about what is being compared. (Source: Reuters, 2024).
What this means in practice: the riskiest claims are often the ones that were written years ago and copied everywhere.
2) Sustainability labels need to be real labels
ECGT targets “self made” sustainability labels.
A key prohibition is displaying a sustainability label that is not based on a certification scheme or not established by public authorities. (Source: Reuters, 2024). (Source: DWF, 2026).
If a product currently uses icons, badges, stamps, leaf graphics, or a “brand label” that looks like a certification, it needs a careful review.
3) Product information also matters
ECGT also improves consumer information in areas linked to product durability and the buying decision. (Source: European Commission, 2024). (Source: Library of Congress, 2024).
This tends to show up in practice as updates to product pages, checkout information, warranty messaging, and customer comms.
What a product company needs to do, step by step
This is the part that actually reduces risk.
The ECGT “Claims to Evidence” workflow
Step 1) Build a claims inventory
Create one list of every sustainability related claim used anywhere, including:
Packaging and inserts
Product pages and FAQs
Category pages and collection names
Ads, email, and social
Brand pages and sustainability pages
Sales decks and retailer line sheets
Include implied claims too, for example symbols, colour cues, and badges that suggest an environmental benefit. (Source: European Outdoor Group, 2025).
Step 2) Classify each claim by type
A simple classification works:
Generic claim: “eco”, “green”, “sustainable”
Specific claim: “made with 50% recycled aluminium”
Comparative claim: “30% less carbon than previous model”
Future claim: “will be net zero by 2030”
Offsetting claim: “climate neutral because offsets”
Label or badge: certification or brand created mark
This makes it obvious where the highest risk sits.
Step 3) Match each claim to evidence
For every claim, record:
What evidence supports it
Who owns that evidence
Whether the evidence covers the whole product
How often the evidence needs updating
If evidence is missing, the claim is not ready for use.
Step 4) Fix, narrow, or remove risky claims
Common fixes that reduce risk fast:
Replace generic phrases with specific, checkable statements
Narrow scope, for example “packaging is recyclable” instead of “fully sustainable”
Remove offset led climate neutrality language from product level copy
Stop using label like graphics that are not tied to a certification scheme
This is where most companies get the biggest immediate win.
Step 5) Put an approval gate in place
Set a simple rule:
No sustainability claim goes live without evidence recorded in the claims register
Marketing, legal, and ESG have a clear sign off process
A review cycle exists, for example quarterly for high volume product lines
Step 6) Keep it up to date
Claims drift over time. Products change. Suppliers change. Copy gets reused.
A lightweight monitoring routine is enough:
Re review top selling product claims monthly
Re review all claims quarterly
Re check labels annually or when certification status changes
Copyable template: ECGT claims register
This is the simplest thing to create and it helps every team.
See example Claims Register Here
https://docs.google.com/spreadsheets/d/1rxWXi6rgMQncEko-bGa0TYpnvsrZlmv67xSAx0gY3Pw/edit?usp=sharing
If this register exists and is maintained, ECGT becomes much easier to manage.
When consultants help, and when they do not
Consultants can help with interpreting local transposition and reviewing tricky edge cases.
Consultants do not solve the ongoing work of collecting evidence, keeping claims current, and managing day to day updates across hundreds of pages and assets.
That ongoing work is operational.
A short note on how Ella fits
Some companies manage the register and evidence process manually, others automate it.
AI ESG agents such as Ella help by keeping the claims inventory, evidence links, and reviews organised, with human expert support for the moments where judgement is needed.
That is usually most useful when product ranges are large, marketing changes frequently, and teams are spread across regions.
FAQ
What is ECGT in the EU?
ECGT is the Empowering Consumers for the Green Transition Directive, Directive (EU) 2024/825. It strengthens consumer protection by tackling misleading sustainability claims and improving key product information. (Source: Directive (EU) 2024/825, 2024).
When does ECGT apply?
EU Member States must transpose by 27 March 2026, and the rules apply from 27 September 2026. (Source: European Commission, 2024).
Does ECGT cover marketing copy and product pages?
Yes. It targets misleading environmental claims and sustainability labels used in business to consumer communications. (Source: Reuters, 2024). (Source: DWF, 2026).
Are generic claims like “eco friendly” allowed?
They are risky. ECGT restricts generic environmental claims unless the company can demonstrate recognised excellent environmental performance relevant to the claim. (Source: Reuters, 2024). (Source: European Outdoor Group, 2025).
Can a brand use its own sustainability badge?
ECGT restricts sustainability labels that are not based on a certification scheme or established by public authorities. Brand created labels that look like certifications should be reviewed carefully. (Source: Reuters, 2024). (Source: DWF, 2026).