On 13 April, at our very first webinar, we had the chance to learn more about the new European regulation governing environmental claims in commercial communications. Generic claims, labels, visuals… what was still tolerated yesterday soon won’t be!
We were delighted to welcome:
- Maxime Van der Meerschen: Co-founder of GiveActions and expert in responsible communication. Co-creator and facilitator of the Greenwashing Fresco.
- Margaux le Gallou: Senior Program Manager at Ecos. Expert in European policy on environmental communication and sustainability standards.
- Bianca Couckuyt: Lawyer at the FPS Economy, in charge of transposing the ECGT Directive.
The webinar was hosted by Clara Michelet, ESG consultant at Bleen and facilitator of the Greenwashing Fresco.
Before getting to the heart of the matter, a little context!
Why did Europe decide to act?
Greenwashing was not legal before the ECGT. In fact, misleading commercial practices were already prohibited at European level. The problem lay mainly in how the rules were enforced and in the lack of clarity around environmental claims.
A European Commission study found that 53.3% of the environmental claims examined in the EU were vague, misleading or unfounded, and that 40% were unsubstantiated. This led to a proliferation of marketing messages that were sometimes vague or difficult to verify.
Faced with this situation, consumers are calling for greater transparency. Many would like environmental claims to be verified before they are published, even though this is not the approach currently taken by EU regulation.
ECGT: a clarification rather than a revolution
The ECGT amends two major pieces of legislation:
- the Unfair Commercial Practices Directive (UCPD);
- the Consumer Rights Directive.
Unlike the parallel proposal for a Green Claims Directive, whose negotiations have been suspended, the ECGT has been adopted and has been transposed into Belgian law since 1 June.
Its main contribution is to write explicitly into EU law several greenwashing practices that were often already punishable under more general principles.
In other words, the logic remains the same: any communication likely to mislead consumers is still a problem. What is new is that certain situations are now identified much more clearly.
ECGT: what the new European directive really changes for your environmental communication
During the webinar, our experts analysed the practical implications of the directive for marketing, communication and sustainability teams. Here are the key points to remember:
Generic environmental claims in the firing line
This is probably the change that will have the greatest impact on marketing teams.
Expressions such as:
- ‘eco-friendly’;
- ‘environmentally responsible’;
- ‘good for the planet’;
- ‘green’;
- ‘sustainable’;
are now considered generic environmental claims when they are not accompanied by precise, visible explanations.
A company that uses this kind of vocabulary must be able to demonstrate recognised, excellent environmental performance. Otherwise, the risk of its communication being deemed misleading rises sharply.
The upshot?
It is better to replace vague statements with specific, verifiable information.
For example:
❌ ‘Our packaging is eco-friendly’
✅ ‘Our packaging contains 65% less plastic than our previous format’
The difference is essential: the second wording explains in concrete terms the environmental benefit being claimed.
Replacing vague statements also applies to product and brand names that include words such as green, eco, natural or climate neutral, which may be considered environmental claims.
The end of carbon neutrality based solely on offsetting
Another major change: ‘carbon neutral’ claims are now particularly tightly regulated.
The ECGT prohibits presenting a product, a service or an organisation as ‘carbon neutral’ when this claim relies mainly on the purchase of carbon credits or other offsetting mechanisms.
The reasoning is simple: even when offset, a product still has a real environmental impact. Presenting it as completely neutral is therefore likely to mislead consumers.
The speakers recommend using more precise wording, for example talking about ‘contributing to global carbon neutrality’ rather than simply ‘carbon neutrality’.
Labels will have to be credible and independent
The ECGT also tackles the proliferation of environmental labels.
From now on, a sustainability label can no longer simply be created and awarded by a company itself. The scheme will have to be based on independent certification or established by a public authority.
For companies, this means greater vigilance:
- check where the label comes from;
- understand how it is governed;
- make sure it is monitored by a third-party body.
Recognised public ecolabels and independent certifications naturally have an advantage in this new regulatory context.
Other practices now explicitly targeted
Beyond environmental claims, the ECGT also introduces new provisions on product durability. Practices explicitly targeted include:
- presenting a product as repairable when it is not;
- concealing the negative impact of a software update;
- exaggerating a product’s lifespan;
- pushing consumers to replace consumables prematurely;
- presenting a legal obligation as a voluntary initiative by the company.
The aim is to give consumers better information while encouraging more sustainable consumption.
Communication between marketing and ESG teams is essential
The key message from this webinar? Prioritise precision.
It is in companies’ best interests to:
- avoid vague environmental claims;
- provide concrete, quantifiable evidence;
- check the robustness of the labels they use;
- drop carbon neutrality promises based solely on offsetting;
- review their communications as a whole, including visuals, slogans and product names.
Good communication and collaboration between the ESG teams, who hold the information, and the marketing teams, who create communications and sales arguments, is essential.
The date to remember
National laws transposing the directive have applied since 27 September 2026, with no exemption for small businesses. If you sell in the EU, every claim on your packaging, website and marketing materials should have been checked before that date. If that is not the case, now is the time to do it.
The directive was originally due to be transposed in the Member States from 27 March 2026.
Where do EU Member States stand? (situation in August 2026)
At that date, 8 Member States had transposed the ECGT Directive: Belgium (transposition completed on 1 June), Germany, Denmark, Ireland, Italy, Lithuania, Romania and Slovakia.
The latecomers include Bulgaria, Czechia, Estonia, Greece, France, Spain, Croatia, Cyprus, Latvia, Luxembourg, Hungary, Malta, the Netherlands, Austria, Poland, Portugal, Slovenia, Finland and Sweden.
