SUMMARY

On 18 May 2026, the European Commission updated the Q&A document on the implementation and interpretation of the Directive on Empowering Consumers for the Green Transition (ECGT). Members can find the document attached.

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The Q&A provides preliminary guidance ahead of the future update of the Commission’s formal guidance notices on the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD). The new rules will apply from 27 September 2026, following Member State transposition by 27 March 2026.

MORE INFORMATION

The Q&A addresses several aspects of the ECGT Directive, including:

• Environmental claims and generic green claims, with the Commission confirming a broad interpretation of environmental claims, including claims that imply a positive, neutral or reduced environmental impact. The Q&A reiterates that broad and unspecific claims such as “green”, “eco-friendly”, “climate friendly” or “environmentally friendly” will generally be prohibited unless traders can demonstrate recognised excellent environmental performance.
• Carbon neutrality and offsetting claims, with the Q&A clarifying that claims such as “carbon neutral” or “climate neutral” will be prohibited where they rely on carbon offsetting outside the product’s own value chain.
• Sustainability labels and certification schemes, with the Commission confirming that sustainability labels will only be permitted where they are established by public authorities or based on recognised certification schemes meeting strict requirements on transparency, independence and third-party verification. Non-compliant labels will need to be adapted or removed before the Directive becomes applicable.
• Future environmental performance claims: the Q&A clarifies that such claims will only be permitted where they are supported by clear and publicly available commitments, detailed implementation plans, measurable targets and regular independent third-party verification.

The document also provides examples of additional issues covered, such as the treatment of packaging artwork that could imply environmental benefits, the use of existing brand or product names, the distinction between generic and specific environmental claims, and the application of the new rules to existing products.

NEXT STEPS

FESI will continue monitoring the implementation of the ECGT Directive, including the developments on the common understanding.