FAQ Direttiva (EU) 2024/825 ECGT "Greenwashing"

FAQ Direttiva (EU) 2024/825 ECGT "greenwashing" / Update 09.2026

ID 26559 | Update 06.10.2026 / Attached (EN)

Update 26 September 2026

This document provides answers to frequently asked questions by stakeholders related to Directive (EU) 2024/825 (ECGT - Empowering Consumers for the Green Transition) of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information.

Any views expressed in this document are the preliminary views of the European Commission (EC) services and may not under any circumstances be regarded as stating an official position of the EC. Only the Court of Justice of the European Union is competent to authoritatively interpret EU law.
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Table of Contents

Questions in relation to the UCPD, as amended by ECGT Directive:

1. Could you clarify the material scope of the ECGT Directive? For example, do corporate communication, sustainability and corporate sustainability reporting fall within the scope of the Directive?2. The definition of ‘environmental claim’ includes claims that ‘imply’ a positive or zero impact on the environment. How should the term ‘imply’ be interpreted in this context? 
3. How are existing brand names or product names that are protected by intellectual property rights, affected by the new rules on environmental claims under the ECGT Directive? 
4. Could you provide further clarification on when an environmental claim is considered generic and when it is not, under the ECGT Directive? 
5. When designing the artwork of packaging, should companies be aware of any elements (e.g. art with green leaves or water drops) that would risk being considered to contain a generic environmental claim or a sustainability label? 
6. How are generic claims of carbon neutrality regulated under the ECGT Directive?
7. How can a trader demonstrate ‘recognised excellent environmental performance’ in order to lawfully use a generic environmental claim under the ECGT Directive? 
8. What is meant by a ‘certification scheme’ under the ECGT Directive? 
9. What types of social characteristics are referred to in the ECGT Directive? 
10. Could you clarify the scope of the prohibition introduced by Annex I point 4c to the UCPD, which prohibits claims that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions when such claims are based on the offsetting of greenhouse gas emissions? 
11. Could you clarify the scope of the prohibition of advertising benefits to consumers that are irrelevant and do not result from any feature of the product or business? 
12. Could you clarify the prohibition of claims related to future environmental performance, in particular concerning the verification by a third-party expert? 
13. To what extent must the method of comparison referred to in Article 7(7) of the UCPD be explained? Should the explanation be understandable to the average consumer? 
14. Can you explain if the term ‘organic’ can be still used as a generic claim? 
15. Do ‘vegan’/ ‘vegetarian’ labels also refer to environmental or social characteristics and qualify as a sustainability label under the ECGT Directive? 
16. Can traders present requirements imposed by law as a distinctive feature when not all products are covered or when the law is from a third country? 
17. The display of sustainability labels is not forbidden if they are established by public authorities. Can this be also third-country public authorities? 
18. How do the new rules on environmental claims and sustainability labels apply to existing products? 

Questions in relation to the CRD, as amended by ECGT Directive:

19. What are the current EU rules on the reparability score for consumer goods?

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	FAQ Direttiva (EU) 2024 825 ECGT - greenwashing September 2026 Abbonati Ambiente	EN	396 kB	0
	FAQ Direttiva (EU) 2024 825 ECGT - greenwashing May 2026 Abbonati Ambiente	EN	394 kB	337