The Directive on Empowering Consumers for the Green Transition (ECGT), adopted in February 2024, marks a key milestone in ensuring consumers receive relevant and accurate information about the environmental performance and characteristics of the products and services they purchase. It amends existing EU consumer protection laws to address misleading environmental claims and unverified sustainability labels. The ECGT introduces clearer rules and stricter substantiation requirements, aiming to foster trust and harmonization across the European Single Market. Member States are required to enact its provisions by 27 March 2026.
The ECGT goes beyond establishing rules on green advertising; it makes sustainability communications a matter of legal and operational responsibility for companies. While regulations such as the EU Deforestation Regulation, the EU Forced Labour Regulation, and the EU Packaging or Battery Regulations focus on the content of products or company practices, the ECGT closes the loop on how companies communicate their environmental and social performance to consumers through advertisements, labels and certificates. Poorly developed, disconnected, or unsubstantiated communication, both internally and externally, about performance in these areas can quickly lead to compliance and reputational nightmares.
Navigating the new Requirements of the ECGT
Compliance with the ECGT requires significant organisational adaptation beyond simple adjustments of a company’s (product and corporate) marketing and communication strategy. The Directive notably enhances the existing EU Consumer Protection Directives (2005/29/EC and 2011/83/EU) by:
- Updating the list of prohibited misleading commercial practices, explicitly including certain environmental claims into Annex I of the Unfair Commercial Practices Directives
- Establishing requirements for substantiating green claims, such as those associated with a ‘recognised excellent environmental performance’ or ‘future environmental performance’ in the form of a transition to carbon neutrality or circularity of products.
- In the case of comparative advertising, requiring traders to provide consumers with detailed information regarding the method of comparison, the products being compared, and the suppliers of those products.
- Establishing minimum standards for sustainability labels by providing a legal definition of what constitutes a ‘certification scheme’ under EU law.
The Unfair Commercial Practices Directive stipulates maximum fines of up to 4% of a company’s turnover in the Member State concerned, or 2 million EUR, in case of non-compliance. Additionally, greenwashing scandals can negatively impact a company’s value by eroding consumer confidence and causing stock market value destruction.
What companies can do?
To meet the ECGT requirements, companies will have to:
- Identify and Categorise Existing Communication: Identify all sustainability-related corporate external communications – including product labels, websites, social media posts and advertisements – and categorise them according to ECGT legal definitions.
- Conduct Gap and Risk Analysis: Before the entry into application of the ECGT, identify potential infringements and compliance risks by systematically evaluating (i) the accuracy and data-availability of existing environmental claims and (ii) the alignment of sustainability labels certification schemes with the ECGT requirements.
- Adapt the Capability Framework: ECGT is about supporting environmental claims with reliable scientific evidence and data, verifying sustainability labels via third-party certification schemes to ensure credibility, and consistently documenting marketing processes for regulatory checks. Companies need to enhance governance and operational processes by clearly defining roles and responsibilities, aligning internal procedures, and implementing robust control systems to manage compliance effectively.
At PwC, we help organizations regain control over their sustainability-related marketing and communication strategies by assessing potential compliance gaps and tailoring practical responses to meet ECGT requirements.
Join us on Friday 20 June 2025, for an insightful webinar exploring the EU’s evolving framework for combating greenwashing. This session will provide practical insights into your risks and obligations as a company in communicating and marketing the environmental and social performance of your products or organisation.
Contact our PwC experts: Christoph Vanderstricht and Lorenzo Costa
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