The ECGT Directive Blacklist: Green Claims Banned Outright in 2026

Part of the confusion around this directive starts with its name. ECGT Directive, EmpCo Directive and Directive (EU) 2024/825 all refer to the same instrument: Empowering Consumers for the Green Transition. It applies from 27 September 2026.

It is not the separate Green Claims Directive — a different proposal the European Commission withdrew in June 2025. That withdrawal changes nothing here: the ECGT Directive is settled law, its transposition deadline passed in March 2026, and it will be applied.

What the blacklist actually is

The ECGT Directive amends the Unfair Commercial Practices Directive (2005/29/EC). Its Annex I is the blacklist proper: a list of commercial practices considered unfair in all circumstances. Everywhere else in the directive you ask whether a practice misleads the average consumer. For Annex I that question does not arise.

This is the most practically important point in the whole directive. For an Annex I claim, no amount of evidence helps. The wording itself is the violation and has to go.

What is newly on the list

• Generic environmental claims without demonstrated excellent environmental performance — "eco-friendly", "green", "planet-friendly", "kind to nature" with no recognised proof (Annex I point 4a).
• Neutrality claims based on offsetting — "climate-neutral", "carbon-neutral", "climate-positive" where the claim rests on offsetting emissions (point 4c). This one catches a very common form of advertising.
• Claims about the whole product when only part qualifies — "made from recycled material" when only the packaging is (point 4b).
• Sustainability labels not based on a recognised certification scheme — self-designed eco badges with no verified scheme behind them.
• Presenting legal obligations as a distinctive feature — what the law already requires cannot be advertised as a voluntary benefit.

Banned is not the same as needs proof

Most environmental claims are not on the blacklist. They stay legal — but only with evidence. "Organic cotton" is fine if you hold a GOTS certificate covering that product. Without it, the identical wording is a violation.

That distinction determines your workload. Annex I claims must be rewritten. Conditional claims must be substantiated — and the evidence has to be attached to the specific claim, not filed somewhere in the company. Treating both the same way means either rewriting too much or too little.

Why this escalates faster in Germany

The directive enters German law through the UWG. The decisive difference from many member states is not the size of the fine but the route to enforcement: in Germany competitors, consumer associations and trade associations can issue a cease-and-desist letter directly. They do not have to wait for an authority to act.

In practice that means your risk does not depend on regulator capacity — it depends on whether a competitor reads your product page. On top of that sit fines of up to 4% of annual turnover in the member state concerned for widespread infringements.

A realistic order of work

1. Clear the blacklist first. Search your catalogue for the Annex I terms — a finite job with a definite end. The full banned and restricted terms reference is the starting point.
2. Then gather evidence. For each remaining claim: does a certificate exist, and does it cover this exact product?
3. Check images separately. Anything printed into a graphic is a claim. An image and label check finds what appears in no text.
4. Rewrite only what is genuinely unsupported. Half of what first looks like a violation is a legitimate claim whose evidence was simply hard to find.
5. Keep a dated record. If you are challenged, what counts is what you checked and changed, and when.

The blacklist is the least pleasant half of this directive but also the most predictable: it is closed, it has no grey zone, and it can be cleared in a single pass. The harder half is evidencing everything that remains legal — and that is not work to leave until September.