Green claims and the ECGT Directive: product data rules

What does the ECGT Directive change for product claims?

The ECGT Directive makes environmental claims and sustainability labels a regulated part of product information across the EU from 27 September 2026. Claims now need evidence, scope and a certification basis, so they belong in governed product data. The product data compliance pillar shows how this fits the wider shift to legally required product data.

Directive (EU) 2024/825 was adopted on 28 February 2024 and published on 6 March 2024. It amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. Member States had to transpose it by 27 March 2026 and apply the rules from 27 September 2026.

The Directive adds four practices to the list of practices banned in all circumstances:

1. Generic environmental claims, such as "eco-friendly", without recognised excellent environmental performance.
2. Sustainability labels not based on a certification scheme or established by public authorities.
3. Claims of neutral, reduced or positive climate impact based on offsetting.
4. Presenting a legal requirement for all products in a category as a distinctive feature.

Claims about future performance, such as climate neutrality by a target year, need a detailed, verified implementation plan. The Directive also requires durability, reparability and guarantee information at the point of sale.

Is the Green Claims Directive still coming?

The Green Claims Directive was proposed in March 2023 and has not been adopted, so the ECGT Directive is the binding rule today. The proposal aimed to set substantiation and third-party verification rules for explicit claims.

For product data, the difference matters less than it seems. The ECGT Directive already requires that claims are specific, provable and not based on offsetting. Any later substantiation rule would add evidence requirements to the same claim records.

Two practical consequences follow. Record the evidence type and verifier with every approved claim, so a future verification rule needs no new data collection. Review claims that rely only on internal studies first, because their evidence is the hardest to defend.

PIMvendors therefore advises building the claim data model now, on the ECGT requirements, with room for verification details. The list below includes the Green Claims proposal as a "proposed" milestone, with the ECGT dates as fixed.

1. 22 March 2023
   Green Claims Directive proposed

   Proposed Directive on substantiating green claims; not adopted as of October 2026, status to be confirmed before relying on it.

   Proposed Source

2. 28 February 2024
   ECGT Directive adopted

   Directive (EU) 2024/825 adopted by the co-legislators and published on 6 March 2024.

   Fixed Source

3. 25 September 2025
   Guarantee notice and label act

   Implementing Regulation (EU) 2025/1960 adopted, defining the EU legal guarantee notice and the GARAN durability label.

   Fixed Source

4. 27 March 2026
   Transposition deadline

   Member States had to adopt and publish national measures by this date.

   Fixed Source

5. 27 September 2026
   ECGT rules apply

   National measures apply; the guarantee notice is mandatory and the GARAN label becomes available.

   Fixed Source

Check the proposal's status before relying on it. This page reflects the position verified on 14 October 2026.

Which product data does the ECGT Directive require?

The ECGT Directive implies a claim record per product and channel, plus durability and guarantee attributes. The table lists the attributes with format and typical source.

In PIMvendors engagements, the hardest attribute is scope. A claim about recycled content in the packaging must not read as a claim about the whole product. That needs separate attributes for product and packaging, linked to PPWR packaging data.

How should a PIM govern green claims?

A PIM should hold claims as structured attributes with an approval workflow, evidence links and expiry dates, and generate marketing copy from them. Claims hidden inside free-text descriptions cannot be audited or withdrawn at scale.

The model that works:

• Claim library of approved claim texts per language, each with evidence, scope and validity.
• Label library of approved sustainability labels, each with its certification scheme, linked to image assets in the DAM.
• Product links that attach claims and labels to products by rule or by hand.
• Workflow that requires sustainability or legal approval before a claim reaches any channel.
• Old stock tracking for products printed before 27 September 2026, with the correction method.

AI-generated descriptions need a guardrail here. PIMvendors considers AI useful for channel-specific descriptions and unreliable for compliance data. Restrict generated copy to approved claims from the library, as explained on the AI product descriptions page.

How do you test green claims governance in a PIM selection?

Test green claims governance with a withdrawal scenario on your own products. PIMvendors' scenario method gives every vendor the same claim set.

1. Load 5 claims with evidence and expiry dates, linked to 100 products.
2. Expire one claim and show every channel where it is withdrawn.
3. Attempt to publish an unapproved label and show the block.
4. Generate a channel description and show that it uses only approved claims.
5. List all products carrying a claim based on a specific certificate.

Score each step on effort and audit trail. Step 2 matters most: withdrawing an expired claim from every channel within a day is the control that protects you when evidence lapses.

Cosmetics and personal care brands make claims at high volume, so the cosmetics and personal care industry page covers the sector-specific data model.