The EU’s Crackdown on Greenwashing: What Suppliers Need to Know, and How EarthShift Global Can Help
Since 27 September 2026, the EU's Empowering Consumers for the Green Transition Directive (ECGT) has banned generic green claims, carbon neutrality claims based on offsets, and self-made sustainability labels. It applies to any business marketing to EU consumers, wherever that business is based, and B2B suppliers will feel it through evidence requests from their customers. This guide covers what has changed, who is exposed, what the penalties are, and five steps suppliers can take now to audit, substantiate and govern their environmental claims.
by Amos Ncube, Senior Sustainability Advisor
The Deadline Is Here
On 27 September 2026, the European Union’s (EU’s) toughest anti-greenwashing rules to date began to apply. From that day, a vague “eco-friendly” on a label, a home-made green leaf logo, or a “carbon neutral” claim built on offsets can be treated as an unfair commercial practice in every EU country.
There is no grace period, and the rules reach existing products already on shelves. They also apply to companies based outside Europe. If you sell, market or ship goods or services to EU consumers, directly or through a retailer, this affects you.
This article explains what has changed, who is exposed, and how EarthShift Global (ESG) can help suppliers get compliant quickly and stay that way.
What the New Rules Say
The law is the Empowering Consumers for the Green Transition Directive (EU) 2024/825, often called ECGT or EmpCo. Rather than creating a new regime, it amends two laws every EU seller already lives under: the Unfair Commercial Practices Directive and the Consumer Rights Directive.
Practices Banned Outright
The headline changes add new practices to the EU “blacklist,” meaning they are banned in all circumstances, with no need for a regulator to prove consumers were misled:
- Generic claims. Words like “green,” “eco-friendly” or “climate-friendly” are banned unless you can show recognized excellent environmental performance, such as the EU Ecolabel. A specific claim on the same medium (“packaging made from 80% recycled content”) avoids the ban but must still be accurate and evidenced.
- Offset-based neutrality. Claiming a product is “carbon neutral” or has a reduced or positive climate impact because of carbon credits bought outside its value chain is prohibited.
- Self-made labels. Any sustainability label must come from a public authority or an independently verified certification scheme. In-house “eco” marks are out, including logos designed to look like labels.
- Partial claims. Presenting a claim about one part of a product or business (for example, the packaging) as if it covers the whole thing.
- Legal requirements as selling points. Promoting something the law already requires of every product as if it were a distinctive feature.
Tougher Tests for Other Claims
Future pledges such as “net zero by 2035” need a detailed, public implementation plan with measurable, time-bound targets, regularly checked by an independent expert. Social claims about working conditions or ethics are caught too.
Brand names, product names, green color schemes and nature imagery can all count as environmental claims. The directive also adds new consumer information duties on durability, repairability and a harmonized legal guarantee notice at the point of sale.
What About the Green Claims Directive?
Its companion proposal, which would have required pre-approval and third-party verification of every green claim, has been stalled since the Commission announced in June 2025 that it intended to withdraw it. Commentators differ on its exact procedural status, but it is not coming into force any time soon. ECGT is the binding law now, and it already demands that every claim be backed by evidence.
Who Is Affected
Any business whose marketing reaches EU consumers is in scope, wherever it is headquartered. A Canadian, US, Latin American, or Asian exporter selling online into France is held to the same standard as a French brand. The rules cover packaging, labels, websites, ads, social media, point-of-sale materials and company-level statements (such as net zero pledges) when they are used to promote products to consumers.
If you only sell to other businesses, you are not off the hook:
- Your customers will ask for proof. EU retailers and brands carry the legal risk for what appears on shelves. They will push evidence requests up the supply chain, and suppliers who cannot substantiate a recycled-content or low-carbon figure risk losing the contract.
- B2B and B2C lines blur. Some countries, such as France, extend consumer-style rules to business communications. Regulators may also compare consumer claims with what appears in supplier or investor documents.
- Sustainability reports can be pulled in. Reporting under the CSRD is generally outside scope, but the Commission’s guidance says that reusing that content in consumer marketing brings it under the new rules.
Implementation is also uneven. Several member states missed the transposition deadline, so national details, penalty levels and enforcement styles will differ market by market.
What’s at Stake
The financial exposure is real. Under EU consumer law, member states must allow maximum fines of at least 4% of annual turnover in the countries concerned, or at least €2 million where turnover data is not available. Many countries set higher ceilings.
Fines are only one route. In Germany and Austria, competitors can get court injunctions within days to stop a claim being used. Consumer groups and NGOs can bring representative actions, and national authorities can coordinate cross-border sweeps through the EU’s Consumer Protection Cooperation network. Because blacklisted practices are banned outright, challengers no longer need to prove anyone was actually misled.
Then there are the practical costs: relabelling or stickering stock, pulling campaigns, rebranding a product line whose name implies a green benefit, and the reputational damage of being publicly named for greenwashing. For suppliers, the biggest risk may be commercial: being dropped by an EU customer who cannot afford the exposure.
On existing stock, national enforcers have agreed a non-binding common understanding. They expect immediate good-faith steps such as correcting online claims, stickering packaging and fixing new orders, and may be flexible case by case where packaging cycles or shelf life cause genuine difficulty.
How EarthShift Global Can Help
Lawyers can tell you what the law says. EarthShift Global helps you prove your claims, organize your data and build the processes that keep you compliant. For suppliers to the EU market, our support typically covers five areas.
Claims Inventory and Risk Audit
We can map every environmental and social claim you make: packaging, product pages, brochures, trade-show materials, social posts, brand and product names, even color and imagery. Each is sorted into keep, improve, evidence or withdraw, prioritized by the EU markets where you sell most.
Substantiation and Evidence Files
For claims worth keeping, we build the evidence behind them: life cycle assessments, product carbon footprints, environmental product declarations, recycled-content reporting and supplier data. We help turn “eco-friendly” into a specific, defensible statement and set up an evidence file you can hand to a customer or regulator on request.
Carbon and Climate Messaging
If your climate story relies on offsets, it needs rebuilding. We help you measure actual emissions across the value chain, set credible reduction targets and, where you want to talk about the future, draft the kind of detailed, independently verifiable transition plan that forward-looking claims now require.
Supply Chain Data Readiness
EU buyers will send questionnaires and evidence requests. We help you collect primary data from your own suppliers, analyze it or report its impacts in a format customers can use, and respond with confidence, turning compliance into a reason to choose you.
Governance, Training and Sign-off
Compliance is not a one-off clean-up. We help design a claims policy, a review and approval workflow before anything goes to market, and practical training for marketing, sales and product teams, so new claims are checked before launch, not after a complaint.
Where to Start This Week
If you have not begun, these five steps cut the most risk fastest:
- Pull every consumer-facing claim, label and logo into one list, including brand and product names.
- Flag anything generic (“green,” “sustainable,” “eco”), offset-based (“carbon neutral”) or self-certified.
- Correct or remove high-risk online claims first; they are the quickest to fix and the easiest for regulators to find.
- Plan stickering or point-of-sale corrections for existing stock, and fix artwork for new orders.
- Ask your EU customers what evidence they will need from you, and start gathering it.
The EU’s message is simple: if you can’t prove it, don’t claim it. Companies that get their evidence in order now will not just avoid fines. They will be the suppliers EU buyers trust with their own reputations.
References
European Commission. Sustainable consumption: Directive on empowering consumers for the green transition and Questions & Answers. Link
Consumer Protection Cooperation Network. (2026, June). Common understanding on old stock situations. Link
Latham & Watkins. (2026, September 9). EU Empowering Consumers Directive: New rules on green claims apply from 27 September 2026. Link
Need help getting there? Contact EarthShift Global for a practical compliance roadmap tailored to the EU markets you serve.