EU anti-greenwashing · ECGT / EmpCo · Directive (EU) 2024/825

Green Claims Check — ECGT / EmpCo (EU 2024/825)

Per-claim ECGT verdict ledger for EU marketing copy

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What is the status, in one line

The ECGT / EmpCo Directive (EU) 2024/825 is in force; national rules apply from 27 September 2026. The 27 March 2026 transposition deadline has passed and 20 of 27 Member States missed it — the Commission opened infringement proceedings on 28 May 2026 (France among the 20; Germany has transposed via UWG amendments).

Official / primary sources:

  • BannedGeneric environmental claims (“eco-friendly”, “green”, “climate neutral”) are prohibited unless backed by recognised excellent environmental performance; whole-product claims when only part qualifies, and self-made sustainability labels not based on a certification scheme, are banned outright.
  • OffsettingClaiming a product has a neutral, reduced or positive environmental impact on the basis of offsetting alone is prohibited — neutrality must rest on verified lifecycle reductions, not bought credits.
  • DeadlineThe directive entered into force Directive (EU) 2024/825; the transposition deadline was 2026-03-27 (passed — 20/27 Member States missed it, Commission formal notices 2026-05-28), and national rules apply from 2026-09-27.
  • SubstantiateExplicit environmental claims must be specific, evidence-based and verifiable. The separate Green Claims Directive proposal — which would have added ex-ante third-party substantiation — was put on hold (Commission announced its intention to withdraw, June 2025).

Last updated 2026-06-13 · ruleset 2026.06, verified against Directive (EU) 2024/825 and the proposed Green Claims Directive. Informational screening, not legal advice — verify against the official regulation or a compliance professional. Read the methodology.

Frequently asked questions

Is this the “Green Claims Directive”?
No. This tool checks the ECGT / EmpCo Directive (EU) 2024/825, which is in force and amends the Unfair Commercial Practices Directive. The standalone “Green Claims Directive” (proposal 2023/0085(COD)) on ex-ante third-party substantiation is a different instrument; the Commission announced its intention to withdraw it on 20 June 2025 and it is on hold with no revival timeline.
When does ECGT / EmpCo apply?
The directive entered into force on 26 March 2024. Member States had to transpose it by 27 March 2026, and the national rules apply to B2C commercial practices from 27 September 2026.
Has France transposed it?
Not yet. France's transposition vehicle is the DDADUE bill, pending before the Assemblée nationale. France is one of the 20 Member States that received a Commission letter of formal notice on 28 May 2026 for failing to communicate complete transposition. Until then the existing UCPD baseline (e.g. Art. L121-2 Code de la consommation) and the separate AGEC ban on “carbone neutre” apply.
Which Member States have transposed it?
As of 28 May 2026, 20 of 27 Member States had NOT communicated complete transposition and received formal notices. Germany is the confirmed example of a State that has transposed (via amendments to the Act against Unfair Competition, UWG). Statuses are indicative — verify locally before relying on an exposure date.
Are carbon-neutral-via-offsetting claims banned?
Yes. ECGT prohibits claiming a product has a neutral, reduced or positive environmental impact on the basis of greenhouse-gas offsetting alone. Self-made or unverified sustainability labels are also prohibited unless based on a certified scheme or established by a public authority.
Is a compliance score from this tool legally binding?
No. The score and per-claim verdicts are a screening aid using deterministic pattern rules. The tool does not certify compliance, does not bind enforcement authorities, and does not replace counsel review for high-risk campaigns.