How the Empowering Consumers for the Green Transition (ECGT) Directive translates to online brand protection

 

The new ECGT Directive (Directive on Empowering Consumers for the Green Transition, No. 2024/825) entered into application on 27 September 2026. This legislation introduces stricter rules against misleading environmental claims, a.k.a. greenwashing, across all EU member states. The new rules ensure that businesses aren’t able to use climate protection as a mere marketing tool anymore.

 

As of this date, unsubstantiated environmental claims like "eco-friendly," "sustainable," or "climate-neutral" in product descriptions, bullet points, or A+ content of online product listings constitute high-risk content and can lead to listing deactivation.

 

But for brand owners, this is much more than a simple compliance issue. If a few sellers in a brand’s distribution network fail to comply with the ECGT Directive, it can trigger takedowns, erode trust, damage channel relationships, and thus compromise the entire network.

 

Therefore, complying with the new rules becomes an online brand protection issue.

 

 

The ECGT Directive in a nutshell

The ECGT Directive aims to ensure that consumers are properly informed about the environmental impact, durability, and repairability of any product before purchase. It applies to all B2C communications, including product packaging, labels, marketplace listings and A+ content.

 

In this sense, the term "environmental claims" refers to non-mandatory messages and representations (e.g., text, labels, symbols, images, brand names and logos) that suggest an environmental benefit. This means that ads, product images, and other visual clues, like a green icon or nature imagery, can also be deemed misleading if they imply unprovable benefits.

 

 

Illustration of product images implying unsubstantiated environmental claims

 

 

The Directive introduces two categories of environmental claims: those that are prohibited under all circumstances and those that are allowed only if they can be properly substantiated.

 

It is prohibited to

• Feature generic, unmeasurable, and unverifiable claims. These include vague marketing terms like "eco-friendly," "green," "environmentally friendly," "sustainable," etc., that provide no verifiable proof for their environmental benefit
• Label a product carbon-neutral if that state is reached by carbon-offsetting alone
• Highlight legal compliance as a benefit
• State unsupported comparison claims without explicitly mentioning, amongst others, the comparison methodology and the exact products being compared
• Use self-created sustainability labels
• Display unverified future claims, like "carbon-neutral by 2035."

 

It is allowed to

• Feature specific and verifiable claims about the energy efficiency, durability, and exact environmental impact of a product, its parts, production processes, and packaging. However, these claims have to be substantiated by publicly available, clear, and objective evidence issued by a reputable independent source
• Issue future claims, like "carbon-neutral by 2035," if backed by measurable targets, a realistic implementation plan, and an appropriate amount of allocated resources. All of this has to be verified by a reputable, independent source.

 

 

Practical ECGT pitfalls on marketplaces

Marketing copy is intended to convince consumers to purchase a product. To reach this goal, marketers tend to rely on persuasive language that highlights the product’s positive features. Lately, with climate protection becoming increasingly important for consumers, arguments embellishing any given product’s environmental benefits have found their way onto product pages.

 

Discover the rise of sustainability in e-Commerce!

 

Now, thanks to the ECGT Directive, brands have to go through these texts with a fine-toothed comb to eliminate any non-compliant claims.

 

High-risk copy includes bullet points containing vague terms, like "nature-friendly," "sustainable," "eco-conscious," A+ content that implies an entire product is environmentally friendly when only a part of it is verified to be that (e.g., recycled packaging), and sustainability badges or logos not issued by recognized independent verification schemes like the EU Ecolabel or the standard EU energy labels.

 

 

Timestamped screenshot of a random product listing on amazon.de taken with our free browser extension screenseal

 

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The screenshot above displays the standard EU energy label to let consumers know about the energy efficiency of the product. When clicking on it, a detailed table appears on screen with all the required specifications.

 

 

Timestamped screenshot of a random product listing on amazon.de displaying the energy efficiency table of the product

 

 

Specific, but non-verified claims are not allowed either. "Made with sustainable materials" isn’t enough. To be able to make such a claim, brands need to display the exact materials as well as the verification process and entity. As stated above, the latter should be a recognized, independent organization.

 

Moreover, information about the product’s durability and warranties must also be specific and verifiable. Where applicable, product listings have to display adequate and clear warranty labels and information.

 

Compliance with the ECGT Directive is monitored by both marketplaces and national authorities. Should a listing fail to comply with the new rules, it has to be removed from the marketplace with its ASIN/SKU deactivated until the seller amends the content.

 

The devil is in the details. While the seller of the above-shown product correctly displays an energy efficiency label issued by a recognized entity, the listing’s copy still has some formulations that may not cut it under the ECGT Directive.

 

 

Timestamped screenshot of a random product listing on amazon.de

 

 

The penultimate bullet point of the text mentions a comparison against unspecified other products, while the last one lists a legally mandated warranty as a benefit.

 

Both of these standard marketing formulations have been used by marketers for decades, but they may violate the new EU rules. 

 

 

Brand protection issues of the ECGT Directive

While the ECGT Directive is a right step toward more transparent environmental protection in e-commerce, it can create serious brand protection issues. The problem is that compliance with the directive is out of the brand’s control, as listing copy, A+ content, and imagery are often set by distributors, marketplace resellers, and affiliate partners.

 

The more complex the distribution network, the harder it is for brands to check whether their partners comply with the ECGT Directive - or any other term of their contracts.

 

Any B2C-facing environmental claim can expose the brand to takedowns, which in turn cause financial and reputational damage. And the risks are many.

 

For example, a distributor may aim to boost conversions and put a green badge on the listing. A reseller could forget to remove the term "eco-friendly" buried in the third bullet point of the listing. Or a marketplace storefront could use colors in its imagery that send an environmental message without adequate verification.

 

The resulting listing deactivations could seriously hinder conversions, disrupt ad campaigns, jeopardize buy box eligibility, and ultimately lead to revenue loss. Moreover, repeated offences could even cause account-level restrictions at various marketplaces and disrupt trust in brands’ distribution networks.

 

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How monitoring sales networks and contract partners can keep listings online

Online brand protection can aid brands in gaining control over the behavior of their distribution networks in general, and the exact content of product listings in particular.

 

For instance, continuous marketplace monitoring not only detects potentially IP-infringing listings, but also highlights unsubstantiated and non-compliant environmental claims in bullet points, A+ content, titles, descriptions, and images. Moreover, it can also flag visual elements like badges and logos that may be interpreted as vague green claims.

 

Brands can set to receive automated alerts for high-risk terms and unverified labels. Such an alert allows brands to intercept non-compliant content and reach out to the responsible merchants before the marketplace and/or the authorities take note of the situation.

 

Compliance with the new ECGT Directive necessitates reformulating partner agreements within distribution networks. Compliant language has to be incorporated into distribution and marketplace agreements, including allowed terms supported by verified authentication, as well as authorized environmental logos and badges to display.

 

Partner compliance is another relevant online brand protection service in this regard, because it can assist brands in mapping authorized sellers and highlighting who controls which listings on which platforms. Once the initial round is complete, partner compliance is also essential in enforcing the new partnership agreements by checking whether distributors follow the newly set rules.

 

It is recommended to do such audits periodically, especially in the case of top-selling products and high-visibility pages, to prevent non-compliant listings from popping up and to ensure continued compliance.

 

 

An action plan for ECGT-resilient listings

As the ECGT Directive is very new, best practices for compliance have yet to be set. However, there are a few suggestions from us at globaleyez that brands can consider for creating ECGT-compliant listings.

 

 

Step 1. Run a risk triage

Brands can create an inventory of all EU-based listings to identify all generic and unsubstantiated environmental claims in text, A+ content, and imagery. All such claims have to be removed, rephrased, or substantiated by accepted verification methods.

 

This applies to content issued by business partners as well, which necessitates reaching out to all authorized sellers, distribution partners, etc., and requesting them to do content reviews as soon as possible.

 

 

Step 2. Substantiation and standardization

For future content, it may be useful to build a library of all approved evidence, test results, certifications, and life cycle assessment (LCA) summaries. This database can serve as a basis for allowed environmental claims in future content.

 

Similarly, A+ templates and image guidelines have to be updated to avoid any unsubstantiated environmental implications, including suggesting beneficial attributes for the whole product when they only apply to parts of it.

 

At this stage, it’s also advisable to create and implement a comprehensive ongoing monitoring process to ensure that all current and future listings comply with the ECGT Directive.

 

 

Step 3. Governance and scale

Going forward, brands should consider embedding ECGT clauses into their partner agreements, including content control, audit rights, and takedown service level agreements (SLAs) to avoid any future misunderstandings or disputes.

 

At this point, brands and sellers can also set up training sessions for all sales and marketing staff to ensure they know what is allowed and disallowed by the ECGT regarding terminology, imagery, verification badges, and substantiation methods.

 

Finally, establishing a recurring compliance review cadence and escalation path for enforcement notices can ensure that potential issues are flagged, analyzed, and dealt with as quickly and efficiently as possible.

 

 

Conclusion

The ECGT Directive significantly changes how brands and sellers can talk about the true environmental impact of their products.

 

While the strict new rules can be beneficial for both consumers and climate protection, marketers in the EU have to face adjustments as they come to terms with the new requirements. Online brand protection measures can aid in monitoring all content for problematic terms and flagging issues to solve before they can become more serious.