The Empowering Consumers for the Green Transition (ECGT) Directive strengthens consumer protection by prohibiting unfounded and vague environmental claims in marketing directed at consumers. It applies to companies that sell and market products to consumers, regardless of industry or size. The directive must be transposed into national law by March 27, 2026, and it must be applied starting September 27, 2026. In Finland, an exception to the timeline has been proposed; the law would become applicable on March 27, 2027. Going forward, environmental claims made by companies will require supporting information and justifications easily accessible to consumers.
What is the Empowering Consumers for the Green Transition (ECGT) Directive?
The EU is currently strengthening consumer protection. The new ECGT Directive, which reinforces consumer protection, was adopted by the EU as early as spring 2024. The core of the directive in terms of practical marketing is clear. After the end of September, unfounded and vague environmental claims directed at consumers—i.e., greenwashing—will be prohibited. This does not mean that companies should remain silent on environmental issues, but rather that claims must be accurate and substantiated, and that consumers must be able to easily access the background information supporting those claims.
The directive’s timeline is already guiding our work. It must be transposed into national law by March 27, 2026, and implemented in practice by September 27, 2026. In Finland, however, a six-month delay in implementation has been proposed according to which it would come into force by March 27, 2027. The transition period was deemed necessary to avoid unreasonable financial burdens on companies as well as significant product and packaging waste.
In practice, this means that despite the delay, it is advisable to review marketing materials, packaging communications, and any proprietary labels well in advance of the final implementation deadline. That way vague expressions and misleading impressions can be corrected in time. It is also important to note that in other EU countries, the original implementation schedule may come into effect earlier compared to Finland—for example, by the end of September 2026.
What does greenwashing look like in consumer marketing?
Ambiguity typically arises when an environmental claim promises benefits without informing the consumer exactly what has been measured, what the comparison is based on, or to which part of the product or life cycle stage the claim applies. In particular, claims such as “carbon neutral,” “climate positive,” and “100% offset” have been vague. The practical impact of the directive is particularly evident in packaging and advertising. For example, packaging for food and other everyday goods may not include claims such as “more eco-friendly,” “lower emissions,” or “smaller carbon footprint” without providing specific background information and justifications to support the claim. Misleading claims are not limited to mere wording. Companies’ own environmental labels, as well as the colors and images associated with claims or labels, can also mislead consumers.
What background information will be required for making environmental claims in the future?
A key change is the requirement for due diligence: claims cannot remain mere advertising slogans. Instead, they must be backed by precise justifications and supporting information. This information must also be made easily available to consumers. This applies to both verbal claims and the labels and imagery created by marketing or packaging.
It is particularly critical that, for example, product carbon footprint calculations are carried out strictly in accordance with standards, using accurate and up-to-date emission factors. If a claim is based on a reduction in emissions, it is essential to explain how this was calculated and to which stage of the product’s life cycle the impact relates. According to the original content, if a product’s emissions are lower due to the choice of raw materials, the claim should be specifically targeted at this stage of production and not overly generalized, for example, to suggest that emissions are lower across the entire product lifecycle.
Who does the ECGT Directive apply to in practice in Finland, and who oversees its implementation?
The directive applies directly to companies that sell and market their products to consumers. It is important to note that the directive does not distinguish between companies based on their size or industry. Therefore, the obligations are not limited to specific sectors but apply equally to, for example, food and other everyday goods. In the future, packaging and consumer marketing must not contain vague claims without specific background information and justifications.
In Finland, the Consumer Agent is responsible for matters related to consumer protection. When assessing whether a claim is misleading to consumers, attention is focused not only on the words themselves but on the overall impression as well. Therefore, it is advisable to also consider the visual elements of the packaging and how the consumer understands the claim.
Does the directive apply to trade between businesses (B2B)?
The directive strengthening consumer protection does not officially apply to business-to-business (B2B) transactions. Nevertheless, B2B companies should not assume they are completely immune to the directive’s effects. There are examples in the Market Court of disputes between companies regarding vague claims. Furthermore, advertising aimed at businesses may also end up being seen by consumers, in which case the communication may effectively resemble consumer marketing, even if the intention was B2B.
Another practical reason relates to customer relationships and purchasing decisions. The company’s own client companies may not want to purchase products that are vaguely marketed or misleadingly advertised. This is due to they themselves wishing to avoid the risk of greenwashing. Misleading environmental claims can thus hinder B2B trade, increase the number of misunderstandings and inquiries, and slow down sales. That is why every company should examine its own marketing from a greenwashing perspective, even if its primary target audience is other businesses rather than consumers.
How do I know if my communication is in order, and what steps should I take going forward?
The directive may understandably raise concerns about whether one might unintentionally engage in greenwashing. In practice, the best way to reduce this risk is to conduct a systematic review. What is being claimed, what the claim pertains to, and whether the supporting information exists and is easily accessible to consumers. It is important to focus on the big picture, rather than individual words. Colors, images, and the company’s own labels can also create a misleading impression.
If you notice any gaps in your own communications or are concerned about the risk of greenwashing, don’t worry! You can book a free, 30-minute consultation with one of our experts, and together we’ll get your environmental communications on the right track.
By using OpenCO2net’s tools and emissions database, you can ensure that your calculations are reliable and support your communications. OpenCO2net’s calculators are based on the GHG Protocol and ISO 14067 standards, and you can also access the most up-to-date emission factors available. We provide full transparency into the background of all calculations and emission factors to support your company’s climate work and reliable communication.
