New rules on environmental claims are approaching. Here’s what companies should do now to prepare.
by Gabriele Ballero, public affairs manager at Cascale
Greenwashing faces a real opponent in the form of European legislators. With consumers increasingly looking for more sustainable products, the way companies communicate environmental performance has been top of the EU policy watchlist for some time.
Alongside relevant country-specific legislation, Cascale’s public affairs team has been following both the Empowering Consumers for the Green Transition Directive (ECGT) and the Green Claims Directive quite closely. While the two are related, they serve different purposes. The ECGT restricts certain misleading or vague environmental claims made to consumers, while the Green Claims Directive was intended to introduce detailed rules on how environmental claims should be substantiated and verified.
Yet while this year ECGT moves to implementation, after the Commission announced its intention to withdraw the proposal, the Green Claims Directive is still stuck in Council. There is currently no clear timeline for whether, or in what form, it may move forward. Even so, companies can take several practical steps now to strengthen readiness.
Actions to Take Now
Don’t delay action. Entering into force September 27, 2026, ECGT will introduce new restrictions on misleading environmental claims. Their immediate priority will be to map all existing environmental and climate claims that companies doing business in the EU have made to consumers.
Brands should convene colleagues across marketing, legal, and product teams to flag any high-risk wording, and vet all packaging, advertising, websites, labels, and product descriptions to ensure compliance with the new rules.
Broad, generic environmental claims without appropriate substantiation will become significantly more restricted under the ECGT. Companies should steer clear of vague claims like “climate neutral,” “carbon positive,” “zero impact,”or “environmentally friendly.” In line with other generalizations, a company cannot market an entire product as “made with recycled material” if only one aspect (such as packaging) contains recycled material. Where recycled-content claims are intended for consumer-facing communications, companies should obtain clear information from suppliers on the scope and percentage of recycled content.
Companies should also exercise caution when making comparative environmental claims. Comparing products based on environmental or social characteristics or circularity aspects such as durability, reparability, or recyclability is increasingly common, but could mislead consumers if comparisons are unclear, incomplete, or not properly substantiated.
Manufacturers should ensure they have appropriate technical evidence supporting recycled-content claims, durability testing, environmental performance claims, and warranty terms. Retailers, traders or resellers are generally responsible for passing on information received from producers, although they are not expected to actively verify or seek information that has not been provided.
Ultimately, the ECGT is not a product disclosure framework — it is a consumer protection and marketing law. Its objective is to ensure that consumers receive accurate and reliable information when making purchasing decisions.
Your 3-month ECGT Readiness Checklist:
- Assemble a cross-functional task force: Convene marketing, legal, and product design teams to flag high-risk environmental or climate claims on all packaging, ads, and digital touchpoints before September 27, 2026.
- Eliminate vague generalizations: Completely phase out sweeping claims like “climate neutral,” “biodegradable,” or “eco-friendly” unless they can be robustly substantiated.
- Secure supplier percentages: Where consumer-facing recycled-content claims are planned, obtain exact, audited percentages and scopes from suppliers.
- Establish technical substantiation: Ensure manufacturers have verifiable durability testing, recyclability metrics, and warranty data ready.
What’s Next for Substantiation
The ECGT represents a sharp shift in how companies communicate environmental performance to consumers. While it introduces broad restrictions on misleading environmental claims, it leaves an important question unanswered: how those claims should be substantiated. That was the role envisaged for the proposed Green Claims Directive, though its future remains uncertain.
In light of this regulatory gap, standardized methodologies and credible sustainability data become increasingly valuable. Tools such as the Higg Index can support companies in strengthening the data, governance and measurement systems that increasingly underpin environmental claims. The adoption of the Apparel & Footwear PEFCR also demonstrates continued EU efforts to promote greater methodological consistency in measuring product environmental performance.
Regardless of the future of the Green Claims Directive, the direction is clear: companies should expect increasing scrutiny of environmental claims and continue strengthening the governance, data, and substantiation processes that support consumer-facing communications.
Cascale Corporate and Affiliate Members can continue exploring these developments during the EU Policy Briefing for Cascale Members on July 20. The member-only session will cover key EU policy updates across corporate sustainability reporting, product sustainability, human rights and due diligence, circularity, and consumer information — including how these developments may affect internal planning, data needs, supplier engagement, and value chain readiness.
Interested in accessing member briefings, expert insights, and opportunities to engage with peers across the consumer goods industry? Learn more about Cascale membership.
Disclaimer: This information is provided for informational purposes only, and should not be construed as legal advice on any subject matter.
Gabriele Ballero is Cascale's manager of public affairs.
