Penalties · ECGT 2024/825
Greenwashing Fines: What a Violation Costs
From administrative fines to revenue deductions — this is the risk for fashion brands. With interactive fine calculator and a scale by company size.
Last updated: June 2026
Bußgeld-Rechner
Max. Bußgeld (4%)
40.000 €
4% von 1.000.000 €
Beispielszenario (1,5 %)
15.000 €
Illustratives Szenario, keine Prognose
Anwaltskosten (est.)
30.000 €
Verteidigung, Verfahren, Korrespondenz
Gutachterkosten (est.)
10.000 €
Sachverständige, LCA, Zertifizierung
Gesamtrisiko (Maximal-Szenario)
Bußgeld + Anwalt + Gutachter (ohne Reputationsschaden)
80.000 €
* Schätzung auf Basis der ECGT-Richtlinie 2024/825 (4% Mindestbußgeld) und typischer Verfahrenskosten. Keine Rechtsberatung. Genaue Beträge hängen von der nationalen Umsetzung und dem Einzelfall ab.
The Legal Basis
ECGT 2024/825
EU Directive
Prohibits generic environmental claims and carbon neutrality claims via offset. The 4%-of-turnover penalty ceiling derives from Art. 13 of the amended UCP Directive (minimum framework for cross-border infringements).
UWG (§ 5, § 5a)
German Law
The Unfair Competition Act covers misleading advertising. Competitors can independently issue cease-and-desist notices and sue.
GWB / Competition Law
Competition Law
The Federal Cartel Office can additionally intervene with large companies if greenwashing has a market-distorting effect.
Fine Scale by Company Size
| Size | Revenue | Min. | Max. | Example |
|---|---|---|---|---|
| Startup | < €1M annual revenue | €5,000 | €40,000 | €10,000–€20,000 |
| Small Business | €1M–€5M | €15,000 | €200,000 | €30,000–€75,000 |
| Mid-Market | €5M–€20M | €75,000 | €800,000 | €100,000–€300,000 |
| Enterprise | > €20M | €300,000 | €800,000+ | > €400,000 |
* Illustrative example values for orientation only — not a prediction. Actual penalties depend on national transposition and the individual case. Not legal advice.
What is worse than the money?
Reputational damage
Greenwashing proceedings are public. A viral NGO report or a major newspaper article can cost more revenue than the fine itself.
Competition lawsuits
Competitors can independently issue cease-and-desist notices and file injunctions under competition law — without waiting for authorities.
Blacklisting
Large B2B customers and platforms (Zalando, About You) have their own sustainability requirements. A violation can lead to delisting.
Lasting damage
Negative press coverage persists in search results. Consumers remember greenwashing cases years later.
What does prevention cost?
| Measure | Cost (est.) | Protection |
|---|---|---|
| TrueGoods Website Scan | Free (basic feature) | Identify all Annex I terms |
| Compliance Tool (Full) | €99–299/month | Ongoing monitoring + reports |
| Legal Advice | €3,000–€15,000 | Legally sound assessment of individual claims |
| LCA Assessment (external) | €15,000–€50,000 | Proof for specific environmental claims |
| Fine (Mid-Market, 4%) | €80,000–€400,000 | — (no protection, costs after violation) |
Frequently Asked Questions
What does the ECGT Directive say about penalties?
Directive 2024/825 requires member states to provide 'effective, proportionate and dissuasive' penalties. For certain widespread infringements it sets a maximum fine of at least 4% of annual turnover. The specifics — amounts, procedure and competent authority — are defined by each country during national transposition.
When do the new rules take effect?
Member states must transpose the directive into national law by 27 March 2026 and apply the rules from 27 September 2026. Whether and how Germany has transposed it on time is best confirmed via official sources such as EUR-Lex and the Federal Law Gazette (Bundesgesetzblatt).
Who will enforce the rules?
This depends on national transposition. Market surveillance or competition authorities are expected to be responsible. Independently, competitors and associations can already act against misleading advertising under existing unfair-competition law (UWG).
How can I reduce my greenwashing risk?
A good first step is to review your environmental claims systematically: which terms do you use, and can you substantiate them? TrueGoods' free website scan flags wording that may be problematic under Annex I of the directive — as a starting point for a well-founded assessment.
Is the information on this page legal advice?
No. This page offers general orientation and does not replace legal advice. Amounts and examples shown are illustrative. For a binding assessment of your specific case, please consult qualified legal counsel.
Further Reading
Avoid fines — here's how
Book a demo and see how TrueGoods checks your website for risky claims before the authorities do.