August 13, 2026
How ClimeCo’s Certified Product Programs Keep You Compliant, Credible, & Consumer-Ready
The clock is ticking. On September 27, 2026, the EU’s landmark Empowering Consumers for the Green Transition Directive (ECGT, also known as EU Directive 2024/825) becomes fully enforceable across every EU Member State. Whether your business is headquartered in New York, Tokyo, or Brussels, if you sell or market products to EU consumers, these rules apply to you — and non-compliance carries fines of up to 4% of your annual turnover.
The good news? ClimeCo’s Certified Product Programs are built to help you meet every critical ECGT requirement for product certification schemes— from Life Cycle Assessments to independent third-party auditing. Here’s everything your business needs to know.
1. The ECGT Directive Is Already in Force — And Becomes Enforceable in September 2026
The Empowering Consumers for the Green Transition (ECGT) Directive (EU 2024/825) entered into force on March 26, 2024, amending two major existing EU consumer protection laws: the Unfair Commercial Practices Directive (UCPD, 2005/29/EC) and the Consumer Rights Directive (CRD, 2011/83/EU). EU Member States were required to transpose the Directive into national law by March 27, 2026, with all rules becoming binding and enforceable on September 27, 2026.
There is no transition period for existing products. If your packaging, website, or point-of-sale materials feature environmental claims or sustainability labels, those claims must comply with ECGT requirements as of September 27, 2026 — regardless of when product packaging or materials were printed or first entered commerce. The European Commission’s own FAQ confirms that “traders” (the term used in the ECGT Directive for product marketers/sellers) have practical options to achieve rapid compliance, including applying stickers over outdated claims on product packaging or deploying corrective QR codes and shelf-talkers at point of sale.
Bottom line: There is no “wait and see.” ECGT enforcement begins September 27, 2026.
2. The Directive Applies to Any Company Selling into the EU — Not Just EU-Based Businesses
One of the most critical and frequently misunderstood aspects of ECGT is its extraterritorial reach. Any company, anywhere in the world, that markets or sells products or services to EU consumers is subject to ECGT’s rules. This is consistent with how the EU has applied the General Data Protection Regulation (GDPR) and other major regulations. If you target EU consumers, EU law governs how you communicate with them.
This means a US-based manufacturer selling through EU retailers, an Asian brand operating an EU-facing e-commerce store, or a global company running EU social media ads. All must comply. The directive covers all consumer-facing commercial practices — not only packaging, but also websites, digital marketing materials, email campaigns, and in-store signage.
Bottom line: If an EU consumer can see your claim, ECGT applies.
3. Vague “Green” Language Is Now Explicitly Banned
This is one of the most sweeping changes in the Directive. ECGT Section 9 explicitly prohibits broad, generic, non-specific environmental claims using terms that consumers cannot independently verify. The following types of language are examples of those terms now banned unless backed by recognized government certification or a compliant third-party certification scheme:
- ❌ “Eco-friendly”
- ❌ “Environmentally friendly”
- ❌ “Climate friendly”
- ❌ “Green”
- ❌ “Gentle on the environment”
- ❌ “Carbon friendly”
- ❌ “Nature’s friend”
These terms are prohibited because they are too vague to substantiate and too broad to verify. ECGT demands that environmental claims be specific, evidence-based, and traceable.
ClimeCo’s program marketing guidelines can provide participating companies with a curated list of ECGT-compliant alternative language and precision-crafted claims that meet the EU’s standards for clarity, specificity, and transparency.
Bottom line: If your sustainability claim can’t be directly verified against a specific ECGT-compliant standard, it’s prohibited.
4. All Sustainability Labels Must Be Backed by a Certified, Third-Party Verified Scheme
Under ECGT Article 1(4), displaying any sustainability label that is not based on a recognized certification scheme and independently verified is explicitly banned. The Directive defines a qualifying certification scheme as one that meets all the following criteria:
| Criterion | Requirement |
| Openness | Open under transparent, fair, and non-discriminatory terms to all willing and able traders |
| Stakeholder Input | Requirements developed in consultation with relevant experts and stakeholders |
| Non-Compliance Procedures | Clear procedures for handling violations, including label withdrawal or suspension |
| Independent Monitoring | Compliance monitored by a competent third party independent from both scheme owner and trader |
ClimeCo’s Certified Product Programs satisfy all four criteria. ClimeCo’s programs are open to any product manufacturer or seller globally, developed with industry experts and LCA professionals, backed by clear non-compliance and decertification procedures, and monitored by ClimeCo with additional independent third-party verification for EU-market sellers.
Bottom line: A logo or label without an independently verified certification scheme behind it cannot legally appear on products sold in the EU after September 27, 2026.
5. Carbon Offset-Based Claims Are Completely Prohibited for Product-Level Environmental Marketing
This may be the single most significant and disruptive provision of the Directive for companies currently using voluntary carbon credits as the basis for their sustainability messaging. ECGT Section 12 contains an absolute prohibition on any product-level environmental claim that cites reliance upon voluntary carbon offsets.
The following types of claims are blacklisted under all circumstances for product-level marketing to EU consumers:
- ❌ “Climate neutral”
- ❌ “CO2 neutral certified”
- ❌ “Carbon positive”
- ❌ “Climate net zero”
- ❌ “Climate compensated”
- ❌ “Reduced climate impact” (if based on offsets)
- ❌ “Limited CO₂ footprint” (if based on offsets)
According to this Directive, offsetting greenhouse gas emissions outside a product’s value chain is not treated the same as reducing emissions within the value chain. Companies may still communicate their support for, and financial contribution to, carbon credit projects in non-product contexts, but those statements must be entirely separated from any direct product environmental or sustainability claims.
ClimeCo’s Certified Product Programs marketing guidelines require that participating companies focus exclusively on direct supply chain product carbon footprint emissions reductions — the actual, verified reduction in a product’s carbon footprint in any EU-facing product environmental claims. This is precisely the type of substantiated, supply-chain-grounded claim ECGT was designed to protect and promote.
Bottom line: If your EU product claim relies on carbon offsets, it must be removed before September 27, 2026. Emphasis must shift to actual emissions reductions within the product’s value chain.
6. Product Carbon Footprints Must Be Scientifically Quantified — and Continuously Reduced
ClimeCo’s Certified Product Programs establish a rigorous, science-based framework that directly addresses ECGT’s substantiation requirements. Each participating company must submit a full Life Cycle Assessment (LCA) compliant with ISO 14067 or the Greenhouse Gas Protocol Product Life Cycle Standard (GHG Product Protocol) to determine the Product Carbon Footprint (PCF) of each product registered in the program, along with a Carbon Emissions Reduction Plan that clearly outlines the company’s planned and any completed PCF reductions, in compliance with EU ECGT requirements.
ISO 14067 and GHG Product Protocol are internationally recognized standards for quantifying and reporting the carbon footprint of a product — encompassing all greenhouse gas emissions across the full product lifecycle, from raw material extraction to end-of-life disposal.
This isn’t a one-time exercise. Under ClimeCo’s program requirements:
- Annual submissions of updated Carbon Emissions Reduction Plans, PCF data, and bi-annual planned and achieved PCF reduction documentation are required
- Companies must commit to ongoing, continual PCF reductions through direct supply chain emissions reductions
- Evidence of achieved PCF reductions through direct supply chain emissions reductions is reviewed and approved by ClimeCo at a minimum bi-annually
This continuous improvement model aligns precisely with what ECGT demands: claims grounded in actual lifecycle impact, both planned and achieved, and neither aspirational nor offset-dependent projections.
Per the EU ECGT amendments to Directive 2005/29/EC
“…making an environmental claim related to future environmental performance without clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan that includes measurable and time-bound targets and other relevant elements necessary to support its implementation, such as allocation of resources, and that is regularly verified by an independent third party expert, whose findings are made available to consumers.”
Bottom line: ECGT-compliant environmental claims require verified, science-based data — not promises. ClimeCo’s LCA-based framework provides the documented evidence trail you need.
7. Independent Third-Party Verification of Certification Scheme Performance Is Mandatory for EU-Market Sellers
For participating companies selling or marketing products to consumers in the EU with a sustainability label based on a product certification scheme, ECGT requires verification of the trader’s compliance with that certification scheme by an independent third-party auditor. This auditor must confirm the trader’s ongoing compliance with ClimeCo Certified Product Program requirements.
ClimeCo has engaged BSI (British Standards Institution) Group as its preferred independent verification body — an ISO/IEC 17065 accredited certification body — to provide objective, third-party monitoring for participating companies seeking ECGT-compliant documentation. Companies that sell in EU marketplaces must opt-in for BSI’s third-party auditing through ClimeCo’s Program Portal.
If a participating company chooses to select its own independent third-party verifier, that verifier must meet all the following requirements and be vetted and approved by ClimeCo beforehand:
- ✅ Legally independent from the participating company
- ✅ ISO/IEC 17065 accredited
- ✅ Experienced in conducting audits of emission reduction measures and supporting documentation
- ✅ Able to document full working knowledge and experience in conducting EU ECGT-compliant audits of traders
- ✅ Fully trained and versed in ClimeCo’s Certified Product Program schemes, at the cost of the verifier
- ✅ Vetted and approved by ClimeCo
Bottom line: Self-certification is not sufficient. EU-facing product claims require verified, documented, independent oversight — and ClimeCo has already built that infrastructure for you.
8. Logo & Program Description Usage Has Specific Rules — and They’re Changing
Effective September 27, 2026, participating companies selling or marketing to EU consumers must use updated ClimeCo Certified Product logos in accordance with the updated Program Marketing Guidelines. These updated logos are specifically designed for ECGT compliance and include two critical features:
- A URL that links directly to a unique registered product webpage outlining how the product, the trader, and the ClimeCo Certified Product Program certification scheme are ECGT compliant — providing regulatory bodies and consumers with transparent, accessible documentation
- Clear identification that the business or product line has fulfilled ClimeCo Certified Product Program requirements through a successful current EU ECGT-compliant audit performed by BSI
Participating companies may only use program descriptions and logos once they have submitted documentation of annual third-party verification of program compliance and received ClimeCo’s approval at the beginning of each certification year. For approved ClimeCo Certified program participants, the approved ClimeCo Certified Product Program logo should be used on packaging, marketing materials, and at point of sale within the EU.
It is the participating company’s responsibility to completely and correctly implement ClimeCo’s Program Marketing Guidelines. Incorrect or outdated logo usage, even inadvertent, represents a compliance gap that could expose your brand to regulatory risk.
Bottom line: Updated EU-compliant logos are not optional. They are your documentation of compliance in the hands of every consumer.
9. The Rules Apply to B2C Only — B2B Communications Have More Flexibility
The European Commission’s official FAQ on ECGT provides an important clarification: the Directive is strictly limited to Business-to-Consumer (B2C) commercial practices. Companies that operate exclusively in B2B contexts — selling only to other businesses, not directly to consumers — have significantly more flexibility, as the B2C-specific rules do not apply to B2B communications.
However, this distinction carries nuance. If your product ultimately reaches consumers through a retail or distribution chain, the consumer-facing marketing materials — packaging, point-of-sale, and direct-to-consumer digital touchpoints — remain subject to ECGT rules. Additionally, some marketing commentators note that the ECGT framework may increasingly influence how investors, regulators, and business partners evaluate ESG communications even in B2B contexts, as the same standards of specificity and substantiation are becoming market expectations.
Bottom line: Pure B2B companies have more flexibility, but if your product reaches EU consumers anywhere in the supply chain, ECGT governs the consumer-facing claims and your direct customer relationship.
10. Non-Compliance Carries Substantial Financial and Reputational Risk
The ECGT Directive is not a voluntary framework or a best-practice guide — it is enforceable law with serious consequences. Under the Directive, the business entity marketing or selling the product to consumers in any EU Member State (the “trader”) is legally responsible for all claims made about its products. Misleading environmental claims can result in:
- Fines of at least 4% of annual turnover in relevant EU Member States
- Mandatory corrective action, including removal of non-compliant claims and labels
- Reputational damage in a market where consumer trust in sustainability claims is already fragile
- Increased regulatory scrutiny as EU Member States ramp up enforcement ahead of and following the September 2026 deadline
National enforcement authorities across the EU have already intensified action against greenwashing, targeting claims about carbon neutrality, circularity, and sustainability across aviation, fashion, logistics, and consumer goods. This enforcement environment will only intensify after the Directive becomes fully applicable.
Bottom line: ECGT enforcement is real, active, and growing. The cost of non-compliance — in fines, remediation, and reputational harm — vastly outweighs the cost of getting certified and staying compliant today.
How ClimeCo Certified Product Programs Support Your ECGT Compliance
ClimeCo’s Certified Product Programs provide manufacturers and sellers with a globally available, credible, ECGT-compliant certification pathway. Here’s how the program is structured to meet every key ECGT requirement:
| ECGT Requirement | ClimeCo Solution |
| Sustainability label based on a third-party ECGT-compliant certification scheme | ClimeCo Certified Product Programs logos — a third-party certified sustainability label |
| Open, transparent certification scheme | ClimeCo Certified Product Programs open to any manufacturer or seller globally under publicly available requirements |
| Independent stakeholder input | ClimeCo Certified Product Programs protocols developed with industry experts, LCA consultancies, GHG specialists, and supply chain professionals |
| Non-compliance procedures | ClimeCo’s Certified Product Programs include clear decertification and logo withdrawal protocols |
| Independent third-party monitoring | ClimeCo has engaged BSI Group as an ISO/IEC 17065-accredited preferred verification body; EU-market sellers must opt in and provide evidence of compliance |
| Science-based product claims | LCAs compliant with ISO 14067 or GHG Product Protocol are required for all registered products |
| Ongoing emissions reductions | ClimeCo requires annual program renewal, PCF submissions, bi-annual review, and confirmation of planned and achieved PCF reductions |
| No offset-based product claims | ClimeCo Certified Product Programs guidelines explicitly prohibit offset-reliant product marketing language |
| ECGT-compliant logo and QR-linked documentation | ClimeCo Certified Product Programs include updated logos with URL linking to ECGT compliance documentation for each registered product |
Compliance Checklist: Your Action Items Before September 27, 2026
- Audit your current EU-facing claims — identify any vague, generic, or offset-based language that must be removed
- Register your products in ClimeCo’s Certified Product Programs and complete ISO 14067-compliant LCAs
- Opt in to third-party auditing through ClimeCo’s Certified Product Programs Portal (or identify and get pre-approval for your own ISO/IEC 17065 accredited verifier)
- Download and implement the updated ECGT-compliant ClimeCo Certified Product Programs logos across packaging, marketing materials, and point-of-sale
- Update your marketing language in accordance with ClimeCo’s Certified Product Programs Marketing Guidelines — replace prohibited terms with ECGT-compliant alternatives
- Separate any carbon credit or offset communications from product-level environmental claims
- Consult legal counsel regarding your specific obligations under ECGT in each relevant EU Member State
Resources
- Public Directory of active, compliant participating companies and registered ClimeCo Certified Products
- ClimeCo Certified™ Product Program and Product Insetting Program Protocols — full program documentation
- Updated logos and EU marketing guidelines for members selling or marketing to EU consumers
- Certification Standard — core certification methodology document; Third-party certification auditor information — details on ClimeCo’s preferred ISO/IEC 17065 accredited independent verification body and how to opt in through the Program Portal
For questions about ClimeCo’s Certified Product Programs and ECGT compliance support, visit ClimeCo.com or contact your ClimeCo program representative.
Frequently Asked Questions
Q: Does ECGT apply to my business if I’m not based in the EU?
A: Any company selling or marketing to EU consumers — regardless of headquarters location — must comply with ECGT rules on sustainability labels and environmental claims.
Q: Can I still mention carbon offsets in my marketing?
A: You may communicate your support for, and financial contributions to, carbon credit projects, but those statements must be completely separated from any direct product environmental or sustainability claims. Product-level claims that rely on carbon offsets are prohibited under ECGT Section 12.
Q: What happens if my products already have non-compliant labels on shelves?
A: The European Commission’s FAQ confirms that traders have practical options, including applying stickers to cover old claims or providing corrective information at point of sale via shelf-talkers or QR codes.
Q: Is a B2B company exempt from ECGT?
A: The Directive strictly covers B2C commercial practices. Pure B2B companies have more flexibility. However, if your products ultimately reach EU consumers through the distribution chain, the trader introducing consumer-facing claims remains subject to ECGT rules.
Q: What is the penalty for non-compliance?
A: Misleading environmental claims can result in fines of at least 4% of annual turnover in relevant EU Member States, along with mandatory remediation and potential reputational damage.
The content of this communication is for general information purposes only. ClimeCo is not a law firm or legal services provider, and this communication is not intended to be legal guidance or advice. Consult qualified legal counsel if you have questions about the applicability of, or compliance with, the laws referenced herein.
Sources & References
- European Parliament and Council. Directive (EU) 2024/825 on Empowering Consumers for the Green Transition. Official Journal of the European Union, March 2024. eur-lex.europa.eu/eli/dir/2024/825/oj/eng
- European Commission. FAQ: Empowering Consumers for the Green Transition Directive. May 2026. commission.europa.eu
- European Commission. New EU Rules to Empower Consumers for the Green Transition Enter into Force. March 2024. energy.ec.europa.eu
- European Commission. Green Claims — Environment. June 2026. environment.ec.europa.eu
- European Parliament and Council. Unfair Commercial Practices Directive (2005/29/EC). EUR-Lex. eur-lex.europa.eu
- European Parliament and Council. Consumer Rights Directive (2011/83/EU). EUR-Lex. eur-lex.europa.eu
- International Organization for Standardization. ISO 14067:2018 — Greenhouse Gases: Carbon Footprint of Products — Requirements and Guidelines for Quantification. iso.org/standard/71206.html
- ClimeCo LLC. Certified Product Program Protocols and Requirements. climeco.com
About ClimeCo
ClimeCo is an award-winning leader in decarbonization, empowering global organizations with customized sustainability pathways. Our team of respected scientists and industry experts collaborates with companies, governments, and capital markets to develop tailored ESG and decarbonization solutions. Recognized for creating high-quality, impactful projects, ClimeCo is committed to helping clients achieve their goals, maximize environmental assets, and enhance their brand. Partner with ClimeCo to drive meaningful environmental change and take your climate initiatives to new heights.
Contact us at +1 484.415.0501, info@climeco.com, or through our website climeco.com.
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