ECGT: what changes in September 2026
The ban on 'carbon neutral' claims and its practical consequences
From 27 September 2026, product-level claims based on offsetting ('carbon neutral', 'CO₂ neutral', 'zero emissions') are banned in the EU by Directive (EU) 2024/825. No transition period. Corporate claims remain possible if documented.
The Empowering Consumers for the Green Transition (ECGT) Directive is a defining regulatory evolution for product communication in 2026. It bans misleading claims and redraws what is defensible. This article details what is banned, what remains possible, and how to prepare.
Directive (EU) 2024/825, product-level enforcement from 27 September 2026.
Banned product claims: 'carbon neutral', 'CO₂ neutral', 'zero emissions', 'climate positive'.
Corporate claims: possible if documented and embedded in a reduction trajectory.
Extraterritoriality: any trader selling into the EU is in scope, regardless of headquarters.
What Directive 2024/825 says
Directive (EU) 2024/825 'Empowering Consumers for the Green Transition', published in the Official Journal of the European Union on 6 March 2024, amends Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights. Its goal: prevent greenwashing practices by framing environmental claims aimed at consumers. Timeline: transposition by Member States by 27 March 2026 at the latest, effective application 27 September 2026. No transition period for product claims. The directive addresses two axes: (1) ban on certain product claims based on offsetting, (2) framing of generic environmental claims ('environmentally friendly', 'sustainable', 'biodegradable'). For carbon credit buyers, axis (1) is the game-changer.
Banned claims at product level
From 27 September 2026, the following claims are explicitly banned when applied to a product: 'carbon neutral', 'CO₂ neutral', 'climate positive', 'climate compensated', 'zero emissions', 'with emissions offset', 'no climate impact'. The ban applies to the claim itself, regardless of any secondary mention ('thanks to certified carbon credits', for example). The logic: a product cannot be 'neutral' in absolute terms, because its manufacturing, transport and consumption always generate emissions. The word 'neutrality' at product level is deemed fundamentally misleading. Sanctions remain in the hands of Member States ('effective, proportionate and dissuasive'). In France, the Consumer Code provides for fines up to €1.5 M for misleading commercial practices, up to 50 % of advertising spend for repeat offences.
What remains possible: documented corporate claims
ECGT targets product-level claims aimed at consumers. At corporate level (annual report, B2B communication, CSR report, financial communication), contribution claims remain possible if documented and embedded in a credible reduction trajectory. Defensible language is that of 'contribution': 'our company contributes X tCO₂eq per year to funding Y climate projects', 'we have reduced our absolute emissions by A % since 2019 and complement with documented carbon contribution'. The VCMI framework (Voluntary Carbon Markets Integrity Initiative) offers three tiers (Silver, Gold, Platinum) depending on ambition. Silver is accessible to companies with a validated SBTi trajectory covering 20 % of residual emissions. To start, Silver is defensive and CSRD-ready.
Extraterritoriality: who is in scope
ECGT applies to any trader selling to EU consumers, regardless of legal headquarters. A US, Asian or UK company selling into the EU is subject to the same claim bans as a French one. That covers: e-merchants selling via a platform accessible in the EU (Amazon Europe, Shopify, etc.), B2C brands present in European retail, exporters directly targeting European consumers. Sanctions are imposed by national authorities of the country where the product is sold, creating a procedural fragmentation risk but a real exposure. For a multinational standardising product communication globally, ECGT requires reworking materials even for non-EU markets if part of production is commercialised in the EU.
ECGT vs Green Claims Directive: do not confuse
A common confusion persists between ECGT and the Green Claims Directive. To clarify. (1) ECGT (Directive (EU) 2024/825) is in force, transposable by March 2026 and applicable in September 2026. It is the active frame. (2) The Green Claims Directive, which aimed to impose ex-ante verification of any environmental claim, was withdrawn by the European Commission in June 2025 after the Council cancelled the final trilogue. It was never formally adopted, is not in force and may never be. If an internal presentation or legal document still cites Green Claims as upcoming legislation, it is outdated. For product communication, only ECGT applies in 2026. This clarification matters because legal teams often confuse the two, delaying compliance.
How to prepare concretely
Four practical steps. (1) Asset audit: list all packaging, digital assets, point-of-sale materials, online product sheets, B2C communication. Identify those containing a 'carbon neutral' or equivalent claim. (2) Replacement plan: define defensible replacement language. For a product certified under a real sustainability approach, shift to descriptive language ('made under documented sustainable standards', 'ingredients from documented regenerative practices') rather than an absolute claim. (3) Withdrawal timeline: plan 12 to 18 months to adapt packaging chains, sell through existing stock, update digital assets. The 27 September 2026 deadline is firm. (4) Internal training: marketing, design, legal, procurement must understand the new rules. Many companies under-estimate the internal coordination effort.
Migrating from 'neutral' claim to 'contribution' claim
A few defensible rewrite examples. Before: 'our product X is carbon neutral thanks to offsetting its emissions'. After: 'manufacturing our product X emits Y kg CO₂eq, which we partially offset by an annual contribution to certified climate projects of Z tCO₂eq'. Before: 'our brand is zero emissions'. After: 'our company commits to an SBTi 1.5°C-validated reduction trajectory, with documented carbon contribution for residual emissions'. The principle: be descriptive, factual, verifiable. The key word is 'contribution', never 'neutrality' at product level. For very visual brands, 'certified contributor' pictograms progressively replace 'carbon neutral' pictograms that were becoming illegal.
27 September 2026: firm deadline. No transition period. Adapting materials takes 12 to 18 months. Starting now is no longer a luxury, it is an obligation.
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