ECGT Explained: New EU Rules on Green Claims (Sept 2026) | NovaSupplier
What You Can No Longer Say About Your Product After 27 September 2026
Matias Santos·
Check your own product page right now. If it says eco-friendly, sustainably made, or responsibly sourced, or if there's a green leaf icon you designed yourself, none of that copy survives 27 September 2026 in its current form.
That's the actual mechanism of ECGT, a new EU directive with no size exemption. It doesn't matter if you're a two-person brand or a listed retailer, the same rules apply on the same date. This guide covers exactly what's banned, what's still allowed, and why a brand sourcing directly from certified manufacturers is already closer to compliant than one relying on an agent.
Check your own product page right now
If it says "eco-friendly," "sustainably made," "responsibly sourced," or "conscious," or if there's a small green leaf icon you or your designer made up for the packaging, none of that copy survives 27 September 2026 in its current form.
That's not a scare tactic. It's the actual mechanism of a new EU directive called ECGT, Empowering Consumers for the Green Transition, and unlike most of the regulation currently circulating in fashion founder groups, this one has no size exemption. It doesn't matter if you're a two-person brand doing €80k a year or a listed retailer. If you sell to consumers in the EU, the same rules apply to you on the same date as everyone else.
That last point is worth sitting with for a second, because it's the opposite of how most EU business regulation works. Nearly everything else phasing in this year, the destruction ban on unsold textiles, the Digital Product Passport, starts with large companies and works down the size scale over years. ECGT skipped that step. It applies to "any trader engaging in commercial practices towards EU consumers," full stop, from the day it takes effect.
What actually changes
ECGT is Directive 2024/825. It doesn't create a new law from scratch, it amends two existing ones: the Unfair Commercial Practices Directive and the Consumer Rights Directive. Member states had until 27 March 2026 to write it into national law, and it becomes enforceable across all 27 countries on 27 September 2026, regardless of how far along each country's own paperwork is. A handful of countries were still finalising their national text as late as April, but that doesn't buy anyone extra time. The application date is fixed at the EU level, not the national one.
What it bans, specifically:
Generic environmental claims, "eco-friendly," "green," "sustainable," "responsibly sourced," used without a specific, substantiated basis. You can still say these things, but only if you can point to exactly what makes the claim true and back it with evidence a regulator or a competitor's lawyer could check.
Climate neutrality claims built on carbon offsetting rather than actual emissions reductions. "Carbon neutral" because you bought offsets is now, specifically, one of the practices the directive names as prohibited. If you want to make a neutrality claim, it needs to reflect real reductions in your own value chain, not a purchased credit sitting outside it.
Self-made sustainability labels and icons. This is the one that catches brands off guard, because it includes design elements, not just text. A little leaf graphic, a "conscious collection" badge, a sustainability score you invented internally, these all count as sustainability labels under the directive's definition, and from September they're only legal if they come from a recognised, independently verified certification scheme or a public authority. GOTS, OEKO-TEX, GRS, Fairtrade, and B Corp all qualify, provided you're actually certified and using the mark within the scope it covers. A badge your design team made in Figma does not.
Future-facing claims without a real plan behind them. "We will be carbon neutral by 2030" is still allowed, but only if it's backed by a public, detailed, time-bound implementation plan that gets independently verified on an ongoing basis. A one-line aspiration on an About page doesn't meet that bar anymore.
What's banned from 27 Sept 2026
What's still allowed
Generic claims ("eco-friendly," "green") without specific substantiation
Specific claims with evidence ("this fabric is 80% recycled polyamide, GRS-certified")
"Climate neutral" based on carbon offsets
Claims based on real, measured emissions reductions
Self-created labels, icons, or scores
Labels from recognised third-party certification schemes (GOTS, OEKO-TEX, GRS, Fairtrade, B Corp)
Future commitments with no verifiable plan
Future commitments backed by a public, audited, time-bound plan
Why the penalties are structured to make this self-enforcing
The maximum fine is up to 4 percent of annual turnover in the country where the violation occurred, which is meaningful on its own. What actually makes this different from a rule you can quietly ignore is who's allowed to bring a claim. Under the Unfair Commercial Practices framework this directive amends, competitors can challenge a rival's green claims as unfair competition, and NGOs have standing too. That turns enforcement into something that doesn't depend on a government inspector noticing your Instagram copy. It depends on whether anyone with an incentive to look is looking, and in a crowded DTC category, someone usually is.
Why this one actually favours a brand your size
Here's the part that gets missed in most coverage of this directive, because most coverage is written for compliance teams at companies with a legal department to hand this to. For a large retailer with hundreds of SKUs across dozens of factories, substantiating every environmental claim at the level ECGT requires is a genuinely large undertaking; it means building traceability into a supply chain that was never designed to produce it.
For a brand producing 150 units of a style through two or three Portuguese factories you actually talk to, most of that traceability already exists. If your factory holds GOTS certification, that's a recognised scheme you can cite directly. If your fabric composition is 100% organic cotton or GRS-certified recycled polyamide, that's a specific, substantiated claim you can make in exactly the form ECGT requires, because you know precisely where the material came from and can ask the factory for the paperwork that proves it.
This is the actual argument for direct relationships over agents in a context that has nothing to do with margin. An agent relationship, by design, adds distance between a brand and the facts a compliant environmental claim now needs. A direct relationship with a certified Portuguese manufacturer is the shortest possible distance between a claim and the evidence for it.
What to do with your product copy before September
Go through every claim on your site, your packaging, and your product descriptions and sort each one into two piles. In the first pile: claims you can trace to something specific, a certification, a material composition percentage, a documented process. Those are fine, and after September you can probably make them more specific and more confidently than before, since your competitors making vague claims will have to strip theirs out. In the second pile: anything that's a vibe, "conscious," "eco," "kinder to the planet," with nothing underneath it. Those need to either get a real basis before September or come off the page.
If you have a self-designed sustainability icon or badge anywhere in your branding, check whether it maps to an actual certification you hold. If it doesn't, it needs to go, or be replaced with the certification mark itself.
Frequently asked questions
It applies to any business selling to EU consumers, regardless of size. Unlike the ESPR destruction ban, which exempts micro and small enterprises, ECGT has no size threshold. A two-person brand and a listed retailer face the same rules from the same date, 27 September 2026.
Generic claims such as "eco-friendly," "green," or "sustainable" used without specific substantiation; climate neutrality claims based on carbon offsetting rather than real emissions reductions; self-created or self-certified sustainability labels and icons not backed by a recognised third-party scheme; and future environmental commitments not supported by a public, verifiable, time-bound implementation plan.
Labels based on a recognised, independently verified certification scheme, or established by a public authority. GOTS, OEKO-TEX, GRS, Fairtrade, and B Corp all qualify, provided the brand actually holds the certification and uses the mark within its certified scope. A brand's own internally designed badge or icon does not qualify.
Fines can reach up to 4 percent of a company's annual turnover in the relevant EU member state. Because the directive amends the Unfair Commercial Practices Directive, competitors and NGOs, not only national authorities, can bring claims against a business's environmental marketing.
ECGT requires environmental claims to be specific and evidenced. A brand sourcing through an agent typically has less direct visibility into a factory's actual certifications and material sourcing. A brand working directly with a certified manufacturer, GOTS, OEKO-TEX, or GRS, for example, can trace a claim straight to documentation the factory already holds, which is closer to what the directive requires than a claim relayed through an intermediary.
The claims worth keeping after September are the ones with a certified factory standing behind them. NovaSupplier connects brands directly to Portuguese manufacturers with real, verifiable certifications, so the sustainability copy on your product page is something you can actually prove.