The new European Union (EU) Directive 2024/825 on ‘Empowering Consumers for the Green Transition’ (ECGT Directive) will start to apply from 27 September 2026.It amends existing EU consumer laws and imposes new consumer information requirements that will require website changes for traders selling to EU customers. It also introduces stricter rules on claims that will impact the way traders can talk about their sustainability credentials. For future environmental claims and sustainability labels, third-party verification will be necessary.

1. New pre-contractual information requirements

The ECGT Directive will require traders to provide consumers with additional, new information before a consumer enters into the contract. These new information requirements will apply for both bricks-and-mortar and online sales. There are also new requirements for both physical goods and digital content.

Physical goods

For physical goods (including those with digital elements), the following new information must be provided:

  • A notice with a reminder about the legal guarantee of conformity and its main elements, including the minimum duration of two years. This notice must follow the template in Commission Implementing Regulation 2025/1960. There are different formats available for online and bricks-and-mortar sales. For example, for online sales, the notice must look like the one pictured below. For in-store sales, the notice can be in black and white, but must be at least A4 in size:
  • If a free commercial warranty is offered lasting more than two years, then a label with information on the commercial warranty must also be provided. This label must also follow the template set by the EU. Again, there are different formats available for online and bricks-and-mortar sales. For example, for online sales, the notice will typically look like the one pictured below, though there is also a version that can be used as a nested display. For in-store sales, the notice can be in black and white. Where it is printed on packaging, it must meet specified dimensions and minimum font sizes.
  • The repairability score, where applicable (e.g., this may be imposed by EU ecodesign rules, currently the only product group subject to this requirement being smartphones and tablets).
  • Information about the availability and estimated cost of, and how to order, spare parts that are necessary to keep the goods in conformity; the availability of repair and maintenance instructions; and about repair restrictions. This does not create an obligation to offer repairs, spare parts or repair or maintenance instructions. However, if they are offered, and producers make this information available to traders, then it must be provided to consumers. The European Commission Q&A clarifies that this does ‘not mean that the producer-trader is obliged to inform the consumer proactively if a product cannot be repaired’.
  • For goods with digital elements, information on the period of time during which software updates will be provided, where that information is available to traders.
  • For online sales, information on environmentally friendly delivery options, where these are available.

Digital Goods

For digital goods (including digital content and services, such as apps) the following new information must be provided:

  • A reminder of the existence of the legal guarantee of conformity for digital content and digital services. This is the legal guarantee established under the regime in Directive 2019/770. Unlike the requirement for physical goods, there is no harmonized template notice for this “reminder”.
  • The minimum period of time during which software updates will be offered.

2. New prohibitions on certain types of claims

The ECGT Directive will ban certain types of claims, including:

  • Generic environmental claims like ‘sustainable’, ‘green’ and ‘energy efficient’,unless traders can demonstrate ‘excellent environmental performance’ (e.g., EU Ecolabel, national schemes such as Germany’s Blue Angel, or top energy efficiency Class A under the EU Energy Labelling Regulation) relevant to the claim.
  • Environmental claims about an entire product or a trader’s entire business when it only concerns a certain aspect of a product or a specific part of a trader’s business.
  • Claiming that a product has a neutral, reduced or positive impact on the environment based on the offsetting of greenhouse gas emissions, such as saying a product is ‘carbon neutral’ or ‘net zero’.
  • Presenting minimum legal requirements as a distinctive feature of a trader’s offer. This means that if a trader is required to achieve a certain environmental target by law, e.g., minimum recycled content in plastic packaging, this cannot be presented as if it is a feature of a trader’s offer.
  • Misleading claims about the longevity of a product. This includes presenting a software update as necessary when it only enhances functionality; falsely claiming that under normal conditions of use a good has a certain durability in terms of usage time or intensity; presenting a good as allowing repair when it does not; inducing consumers to replace or replenish consumables of a good earlier than necessary; and withholding information concerning functional impairment when consumables, spare parts or accessories from a third party are used, or falsely claiming that such impairment will happen.

3. New rules on sustainability labels – including third-party verification

The ECGT Directive introduces new requirements that impact traders using sustainability labels.Sustainability label is defined to include any trust mark, quality mark or equivalent distinguishing a product or business by virtue of its environmental or social characteristics, e.g., B Corp, Global Organic Textile Standard (GOTS), Fairtrade and the Forest Stewardship Council (FSC).

From 27 September 2026 onwards, all sustainability labels used in the EU must either be established by a public authority or based on a certification scheme that complies with the ECGT Directive’s requirements. If this is not the case, the sustainability labels can no longer be used by traders in the EU.

Certification schemes underpinning sustainability labels need to meet requirements on transparency, openness and credibility and the trader’s compliance with the certification scheme’s standards must be verified by a third party that is independent from both the scheme owner and the trader.

While in practice compliance requires sustainability certification providers to take action, traders who display the sustainability label or certification remain legally responsible for only displaying sustainability labels based on a compliant certification scheme.

4. New requirements for claims relating to future environmental performance – also including third-party verification

The ECGT Directive bans claims related to future environmental performance, such as claims that a business ‘will become carbon neutral’ or that a product ‘will be made of fully recycled materials in the future’, unless these claims comply with the following:

  • The claims are based on clear, objective, publicly available and verifiable commitments;
  • The commitments are set out in a detailed and realistic implementation plan that includes measurable and time-bound targets and other relevant elements necessary to support its implementation, such as resource allocation;
  • The implementation plan is regularly verified by an independent third-party expert; and
  • The findings of the independent third-party expert are made available to consumers.

5. Enforcement and implementation

EU Member States are required to adopt national legislation to implement the new rules. There may be differences between different EU Member States in how they implement the ECGT Directive. Germany, for example, applies certain rules on misleading commercial practices to certain B2B transactions. However, the legislative amendment adopted to implement the ECGT Directive into German law expressly limits the requirements for claims about future environmental performance, for example, to B2C contexts.

The ECGT Directive will be enforced by the regulatory authorities of each EU Member State.

Fines for noncompliance can be up to 4% of a trader’s annual turnover in the relevant EU Member State (or more if the relevant EU Member State sets a higher maximum under national law). The relevant consumer laws are also in scope of the EU’s Representative Actions Directive, which allows claimants to bring class-action-style claims in the EU based on noncompliance with these obligations.

With just over six months until the new requirements start to apply, traders operating in the EU are advised to review their websites, product packaging and any other marketing claims for compliance. They should also check their websites and sales flows to make sure that they are compliant with the new consumer information requirements, in particular that they are showing customers the EU harmonised notice and label where required.

Key takeaways:

  • Effective 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive introduces new requirements for traders offering goods and services to consumers in the EU.
  • New pre-contractual information requirements will be introduced impacting every retailer in the EU, including an obligation to show customers a harmonised notice as a reminder of the minimum two-year guarantee.
  • Certain types of claims will be banned in the EU, including generic claims like ‘sustainable’ and ‘carbon neutral’ claims based on offsets.
  • Sustainability labels can only be used if compliance is monitored by an independent third party.
  • Claims about future environmental performance trigger obligations to have an underlying implementation plan and commitments that are verified by an independent third party.

If you have any questions, please contact the Cooley EU Products Team.

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