The ECGT Directive Playbook: what EU companies need to know and do

News

26-03-2026

1 minute read

The Empowering Consumers for the Green Transition (ECGT) Directive introduces a new EU‑wide framework to combat greenwashing and social washing across all consumer markets. By 27 March 2026, Member States must transpose the Directive into national law. A six-month material grace period will then apply, meaning that as of 27 September 2026, all EU‑based companies offering consumer‑facing products or services must fully comply.

The ECGT Directive raises the bar for sustainability‑related communications. Generic terms such as “eco‑friendly”, “green”, “sustainable” or “responsibly sourced” may only be used when supported by robust, verifiable evidence or a qualifying certification scheme. The ECGT Directive also introduces new blacklisted commercial practices, increases litigation exposure, and tightens supervisory expectations across the EU.

Although the ECGT Directive is rooted in EU consumer protection law, its effects extend beyond the consumer domain. The categorisation of certain environmental and social claims as inherently misleading in a consumer context influences the broader European normative landscape. These standards increasingly shape what stakeholders – including regulators, NGOs, competitors and market participants – may reasonably expect in terms of accuracy, restraint, and substantiation when companies communicate about sustainability, social issues or human‑rights‑related topics. In several jurisdictions, including the Netherlands, these evolving expectations can also play a role in the assessment of potential greenwashing or social washing risks under general tort principles, particularly where public statements create overly positive or misleading impressions regarding environmental or societal performance.

To support companies in preparing for these upcoming obligations, we have developed the ECGT Directive Playbook: What EU companies need to know and do before 27 September 2026. This practical guide outlines the ECGT Directive’s scope, the newly blacklisted practices, substantiation requirements for environmental and social claims, and the rules governing sustainability labels and certification schemes. It also sets out the key steps companies should take during the grace period and provides a clear starting point for companies to map and reduce their exposure under the upcoming ECGT Directive.

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Our specialists are closely monitoring these and other climate change litigation developments and potential ESG liability and litigation risks in this respect. Please do not hesitate to contact any of us for more information.