With the Empowering Consumers for the Green Transition Directive (EU) 2024/825 (ECGT), the days of vague green marketing are numbered. Terms such as “eco-friendly” and “carbon neutral” have become a fixed part of product marketing. Too often, they are empty or outright misleading.

The Union’s aim is clear: remove unsubstantiated claims, protect fair competition between producers, and make it easier for consumers to choose sustainable products. For cosmetics and food brands, this touches the pack, the shelf, the website and, in some cases, the brand itself.

What changes on 27 September 2026?

The ECGT does not create a new regulator or a new registration duty. Instead, it amends the Unfair Commercial Practices Directive (UCPD), a framework national consumer authorities have enforced for almost two decades. The key changes:

• New blacklisted practices. Several green claims are added to Annex I of the UCPD, the list of commercial practices considered unfair in all circumstances.
• No case-by-case assessment. For blacklisted practices, authorities do not need to show that the average consumer was actually misled. If the practice is on the list, it is prohibited.
• National enforcement. Member States enforce the rules and set the penalties, within the UCPD framework.

How far does the directive reach?

Further than many brands expect. A Commission study from 2020 found that around 40% of the environmental claims examined were unsubstantiated. The ECGT targets that gap, and not only on the label itself.

What counts is the overall impression given to the average consumer. That can include:

• Product and brand names that suggest the product is better for the environment.
• Artwork and imagery, such as leaves, water droplets or green fields.
• Online and in-store communication, not only on-pack text.

A green logo, or the word “eco” in a brand name, is not misleading on its own. However, when such elements are combined with text or claims, they become part of what the consumer is taken to have understood. The more elements point in the same direction, the harder it becomes to argue that no environmental message was intended.

Generic claims: what the term actually means

The most consequential change for marketing teams is the ban on generic environmental claims that cannot be backed by recognised excellent environmental performance.

Under the amended UCPD, a generic environmental claim is an explicit environmental claim that is not included on a sustainability label, and where the specification of the claim is not given in clear and prominent terms on the same medium. In other words: a broad statement, with no concrete explanation next to it.

Typical examples listed in the recitals include:

• “environmentally friendly”, “eco-friendly”, “green”, “ecological”
• “climate friendly”, “gentle on the environment”, “carbon friendly”
• “biodegradable”, “biobased”

Such a claim is only allowed where the trader can demonstrate recognised excellent environmental performance. That route is narrower than most brands assume. It covers:

• the EU Ecolabel;
• a national or regional EN ISO 14024 Type I ecolabel officially recognised in a Member State, such as the Nordic Swan or the Blue Angel; or
• top environmental performance under other applicable Union law.

Carbon neutral? Only if the product earned it

Carbon offsetting has been an easy way for companies to show commitment to sustainability, and offsetting in itself is not a bad thing. The problem has been using offsets bought elsewhere to present a product as climate neutral. That is now blacklisted.

• Prohibited: claims that a product has a neutral, reduced or positive greenhouse gas impact, where the claim is based on offsetting. The recitals mention “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero”, “climate compensated”, “reduced climate impact” and “limited CO2 footprint”.
• Still possible: claims grounded in the product’s own lifecycle, for example a reduced CO2 impact based on real changes to formulation, sourcing or production, specified on the same medium.
• Also still possible: communicating about investments in carbon credit projects, as long as these are not presented as a property of the product.

Sustainability labels: no more self-awarded seals

Displaying a sustainability label is prohibited unless it is established by a public authority or based on a certification scheme. The directive defines what such a scheme must involve, and the bar is higher than before:

• Third-party verification.
• Publicly available requirements.
• Monitoring by a competent body independent of both the scheme owner and the trader.
• Openness to all traders willing and able to comply, on fair and non-discriminatory terms.
• Requirements developed in consultation with relevant experts and stakeholders.

The Commission has further indicated that the scheme owner and the monitoring body must be separate legal entities, and that labels established by non-EU public authorities do not benefit from the public-authority route. Such labels are lawful only if they rest on a qualifying certification scheme.

Where does this leave brands?

For most brands, the ECGT will not turn their marketing upside down. For those it does affect, getting claims and labels in order now can prevent costly enforcement and rebranding later.

There is also an upside. In an EU market where product claims are already tightly regulated, differentiation is difficult. Brands with specific, substantiated and properly certified claims will now stand out from those relying on unverified wording. The directive effectively rewards precision.

How Knudsen&CRC can help

Since 2012 we have worked with cosmetics and food brands on regulatory compliance in the EU, the UK and China, and the questions this directive raises are ones we deal with daily. We can go through what your products actually say, on pack, on shelf and online, including product names and artwork, and tell you which claims need specifying, which need better evidence, and which need to come off.

Where a claim is worth keeping, our claims’ testing work is aimed at producing evidence someone outside your business can check. Where a claim rests on a label, we can assess whether the scheme behind it meets the conditions in the directive and help you get a certification that does. Feel free to contact us at info@knudsencrc.com.