EU Directive 2024/825
EU Directive ECGT 2024/825: What Fashion Brands Need to Know
The Empowering Consumers for the Green Transition Directive — explained simply for marketing teams. Deadlines, Annex I terms, fines and a step-by-step checklist.
Last updated: June 2026
TL;DR – 5 Key Points
- The EU adopted the ECGT Directive in March 2024, prohibiting blanket environmental claims without proof.
- Germany transposed the Directive into national law in March 2026; enforcement begins on 27 September 2026.
- Terms like 'climate-neutral', 'sustainable', or 'eco-friendly' are risky without a recognised certificate.
- Enforcement is carried out by national market surveillance authorities; fines can reach up to 4% of annual revenue.
- Fashion shops must check and, where necessary, revise product pages, campaign copy, and sustainability sections.
What is the ECGT Directive?
Directive (EU) 2024/825 – known as ECGT – was published in the EU Official Journal on 6 March 2024 and entered into force on 26 March 2024. It amends Directive 2005/29/EC (the UCP Directive) and adds new prohibited practices to Annex I. Its aim is to protect consumers from misleading environmental claims (so-called greenwashing) and to ensure fair competition.
What changes for fashion brands?
No more generic environmental claims
Claims like 'sustainable', 'eco-friendly', or 'organic' are prohibited without an EU Ecolabel or a national ISO 14024 Type-I standard.
Carbon neutrality claims are heavily restricted
Product-level carbon neutrality claims based on CO₂ offsets are categorically prohibited.
Future commitments require milestone plans
Those promising 'carbon-neutral by 2030' need a publicly accessible, third-party-audited action plan with time-bound interim targets.
Comparisons require methodology and source
Claims such as 'more sustainable than competitors' require a published comparison methodology and verified data.
The Most Important Annex I Terms
| Term | Annex | Risk |
|---|---|---|
| klimaneutral | Annex I, 4c | Critical |
| nachhaltig | Annex I, 4a | High |
| umweltfreundlich | Annex I, 4a | High |
| CO₂-neutral | Annex I, 4c | Critical |
| grüne Kollektion | Annex I, 4a | High |
| bio (ohne Zertifikat) | Annex I, 4a | High |
| netto-null | Annex I, 4c | Critical |
| ethisch produziert | Annex I, 4a | Medium |
| wird klimaneutral | Art. 6 UGP-RL | High |
| nachhaltiger als die Konkurrenz | Art. 7 UGP-RL | High |
All 50+ terms with alternatives: forbidden-terms →
What are the Penalties?
| Company Size | Min. Fine | Max. Fine | Likely Range |
|---|---|---|---|
| Startup (< €1M revenue) | up to €40,000 | up to €40,000 | €10,000–€20,000 |
| SME (€1M–€10M) | 1% of revenue | 4% of revenue | 1.5% of revenue |
| Enterprise (> €10M) | 1% of revenue | 4% of revenue | 2% of revenue |
Calculate your personal risk: Fine calculator →
What must you do by September 2026?
Scan all product pages, campaign copy, and sustainability sections for Annex I terms.
Check all environmental claims against existing, recognised certificates (EU Ecolabel, GOTS, Blue Angel, etc.).
Remove or revise carbon neutrality claims without external audit and milestone plan.
Substantiate comparative claims with methodology, source and date – or remove them.
Introduce an internal approval process for new marketing claims that checks ECGT requirements.
Frequently Asked Questions
What does ECGT stand for?
ECGT stands for 'Empowering Consumers for the Green Transition' – an EU directive that protects consumers from misleading environmental claims.
Does the directive apply to all companies?
Yes, to all traders offering products or services in the EU – regardless of company size or location.
What is the difference from ESRS and CSRD?
CSRD/ESRS concerns sustainability reporting by large companies. ECGT regulates specific marketing claims towards consumers – both frameworks complement each other.
Do I need to revise all existing marketing copy?
All claims that fall under Annex I or cannot be backed by recognised certificates must be adjusted or removed.
What is a 'recognised certificate' under the Directive?
The EU Ecolabel (Reg. 66/2010) or nationally recognised ISO 14024 Type-I standards such as the Blue Angel. Internal seals or self-created labels are insufficient.
Detect and fix ECGT risks
Book a demo and see how TrueGoods checks your product pages and campaign copy for ECGT violations.
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