ECGT vs Green Claims Directive — What Was Withdrawn and What Remains
In 2023, the European Commission pursued two parallel legislative tracks to regulate corporate environmental marketing claims: the Empowering Consumers for the Green Transition (ECGT) Directive (2024/825) and the Green Claims Directive (GCD).
The GCD aimed to establish detailed scientific substantiation and third-party verification requirements for environmental claims. However, under the von der Leyen Commission's second term, it was officially withdrawn in June 2025 as part of the omnibus simplification package intended to reduce regulatory burden on businesses.
The ECGT, meanwhile, was adopted by the European Parliament and Council in February 2024, with a member state transposition deadline of March 27, 2026 and an enforcement date of September 27, 2026. With the GCD gone, the ECGT has effectively become the primary regulatory framework governing environmental marketing claims in the EU.
What Changes on September 27, 2026
The ECGT amends the existing Unfair Commercial Practices Directive (UCPD) to directly prohibit deceptive environmental marketing. Three key changes stand out.
Banned Generic Environmental Claims
Broad terms such as "eco," "green," "environmentally friendly," "biodegradable," and "climate neutral" cannot be used without recognized certification or scientific evidenceCarbon-neutral claims based solely on carbon offset purchases are outright banned — companies can no longer label products or operations as "carbon neutral" simply because they purchased emission creditsUnsubstantiated claims about product durability and repairability also fall under regulationSustainability Label Restrictions
Self-created sustainability labels not grounded in official certification schemes are prohibitedOnly recognized certifications such as the EU Ecolabel, GOTS, and OEKO-TEX are permittedPenalties for Non-Compliance
Penalties are determined by individual member states but must be "effective, proportionate, and dissuasive"Under the existing UCPD framework, fines of at least 4% of annual turnover in the affected member state can be imposed for widespread infringementsRemedies may include corrective orders, sales suspensions, and product recallsKorean Export Sectors and Products at Risk
The following Korean export industries frequently use environmental marketing claims that will come under direct scrutiny.
Cosmetics and Beauty
Claims such as "95% naturally derived," "clean beauty," and "eco formula" are directly targetedWithout scientific substantiation and recognized certification (e.g., COSMOS, NATRUE), market access to the EU will be restrictedElectronics and Appliances
Packaging and advertising claims like "30% energy savings," "green product," and "eco mode" must be reviewedEnergy efficiency claims should be linked to EU Energy Label ratings to ensure defensibilityFood and Beverage
Claims including "organic," "carbon-neutral manufacturing," and "sustainable packaging" require supporting documentationOrganic claims must comply with EU Regulation 2018/848 certification, and carbon-neutral claims are prohibited if based solely on offsetsTextiles and Fashion
Claims such as "sustainable materials," "100% recycled," and "eco fabric" require third-party certificationQuantitative verification of recycled content and certification through GOTS or GRS becomes effectively mandatoryFive-Step Environmental Marketing Claim Self-Audit
Export companies should begin the following process immediately.
Comprehensive inventory — Catalog every environmental claim across product packaging, catalogs, websites, and social media advertisingEvidence verification — For each claim, confirm whether scientific data, test reports, or certifications exist. Classify any without supporting documentation as "insufficient evidence"Secure LCA data — Environmental claims lacking Life Cycle Assessment data carry the highest risk. Commission third-party analysis if internal capabilities are insufficientTransition to recognized certifications — Replace self-declared labels with officially recognized schemes such as the EU Ecolabel or ISO 14024 Type I certificationsCross-functional review — Legal, marketing, and quality departments should jointly review revised claims and proactively notify trade partners and buyers of changesKorea Fair Trade Commission Guidelines and Dual Compliance
Environmental marketing regulation is tightening domestically as well. The KFTC's Guidelines on Environmental Advertising require that environmental claims be truthful, specific, and substantiated.
The 2025 revision strengthened substantiation standards for carbon-neutral and net-zero claims and clarified enforcement procedures including corrective orders and fines for greenwashing violationsThe Korea Environment Corporation's green management labeling standards operate environmental performance marks and carbon footprint certifications, with ongoing exploration of mutual recognition possibilities with EU frameworksFor exporting SMEs, building a single compliance framework that satisfies both EU ECGT and domestic KFTC guidelines is the most efficient approach. Establishing an environmental claim management process based on ISO 14001 (Environmental Management Systems) enables integrated compliance across both regulatory regimes.
How KITIM Can Help
KITIM provides ISO 14001 certification consulting, ecolabel certification support, LCA analysis coordination, and environmental marketing claim audit services. We offer end-to-end support for EU exporters — from ECGT response strategy development to packaging and advertising revisions and certification acquisition. If your company needs proactive preparation before the September 2026 enforcement date, contact our consulting team today.
