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Written by Gwladys Lecomte and Auguste Chameroy
What to remember :
- ECGT and EmpCo refer to exactly the same European directive: (EU) 2024/825
- It aims to combat greenwashing and to better regulate Sustainable Development Labels and generic environmental claims
- It applies to B2C companies, but may also concern certain B2B companies
- Its scope is broad: generic claims, non-certified labels, unproven future commitments
If you have come across "ECGT" in an official document and "EmpCo" in a consulting firm article, and wondered if they were two different regulations: no, it is the same thing. Here is everything you need to know about this directive before it comes into effect on September 27, 2026.
ECGT, EmpCo: two names, one text
ECGT is the acronym used in the official documents of the European Commission, for "Empowering Consumers for the Green Transition". EmpCo is an abbreviation of the same name, more often used by law firms, consulting firms, and in professional communication. Both refer to the same text: the directive (EU) 2024/825, adopted on February 28, 2024.
Vocabulary point:
European directive: a text adopted by the European Union that sets a target to be achieved, with each member state responsible for incorporating it into its own national law (unlike a European regulation, which applies directly, without transposition).
Why this directive exists
Labels and environmental claims have multiplied in corporate communication in recent years, but not all of them are equal. Some are solid and verifiable, while others are exaggerated or even pure deception. This situation has ultimately eroded consumer trust in environmental communications in general.
Several countries, including France, had already established initial rules to limit this phenomenon (in France, the Climate and Resilience Law in particular). The ECGT/EmpCo directive aims to harmonize these rules at the European Union level, with a broader and more precise text.
What the directive concretely covers
The directive addresses four main topics:
- Frame sustainable development labels by imposing serious criteria (independent audit, transparency of standards...)
- Avoiding misleading environmental claims (strictly defined greenwashing)
- Avoiding misleading information about the social or environmental characteristics of a company
- Combating planned obsolescence (a section that we do not address in this guide, distinct from the claims/labels topic)
Who is affected?
The EmpCo directive applies to all companies, whether they operate in B2C or B2B. It does not target a specific type of activity or clientele: it falls within the framework of misleading business practices, which covers both relationships with end consumers and inter-business relationships.
Any organization that communicates about its environmental commitments (regarding its products, services, or brand image) may be affected if its claims are not verifiable, documented, and compliant with the requirements of the directive.
The timeline at a glance
- February 28, 2024 : adoption of the directive
- March 27, 2026 : deadline for transposition into national law — not met by France
- September 27, 2026 : entry into application in the 27 EU countries
🔗 Learn more : what applies concretely in France starting September 27
What the directive specifically prohibits
The directive lists 13 business practices considered misleading. Among the most common: unsupported generic environmental claims ("eco-friendly", "environmentally friendly"), "carbon neutral" labels based solely on carbon offsetting, or highlighting legal obligations as if they were a distinctive advantage.
Label or rating? A distinction not to be confused
Not all CSR evaluation mechanisms automatically fall under the same obligations. The directive specifically targets the sustainable development labels. The platforms for rating, which deliver a score rather than a label in the strict sense, do not exactly follow the same logic. This distinction is actually a topic of debate among industry experts: some rating agencies consider themselves outside the scope of the directive, while other legal analyses include them as examples of already compliant systems. The subject remains to be clarified as the first official interpretations unfold.
What sanctions in case of non-compliance?
At the European level, the directive sets a minimum sanction of at least 4% of annual revenue. In France, Article L. 132-2 of the Consumer Code allows for more: a fine of €300,000, which can be increased to 10% of the revenue from the last three years or 50% of the advertising expenses related to the practice in question, with possible prison sentences in the most serious cases.
It should be noted that these sanctions will apply to labeled organizations and not to the entities holding the Sustainable Development Labels.
What the directive changes for sustainable development labels
This is one of the most structuring aspects of the directive for organizations like Positive Company®. A private sustainable development label must now meet several criteria to continue to exist after September 27, 2026:
- An audit system conducted by a third party independent
- Publicly available attribution standardsA
- non-discriminatory opening to any organization that meets the criteriaStandards established
- in consultation with external stakeholdersA
- Un management mechanism for non-conformities, which may lead to the suspension or withdrawal of the label
Labels that relied solely on internal self-assessment, without verification by a third-party organization, will need to disappear or transform.
To compare the main CSR labels on the market against these criteria, consult our dedicated guide: Which CSR label to choose for your company?
Purpose and mission-driven company: special vigilance
Companies that communicate about a purpose, a mission, or statutory commitments are also concerned as long as these elements are used for marketing purposes and have an environmental dimension. Formulated broadly or abstractly ("contribute to the common good", "sustainable future"), these formulations can be reclassified as generic claims.
Conclusion
This directive does not seek to prohibit companies from communicating about their environmental commitments; it seeks to ensure that what is said can be proven. For labeling organizations as well as for companies that communicate about their own commitments, the watchword is now the same: proof takes precedence over promise.
Label RSE Positive Company® : une démarche de mise en conformité déjà menée
Verification by an independent third party, public reference, management of non-conformities: the RSE Positive Company® Label meets the requirements that the directive now imposes on all sustainability labels.
Discover our ECGT compliance approach Learn moreFAQ: ECGT / EmpCo, The complete guide
No, they are two names for the same European directive (EU) 2024/825.
On September 27, 2026, in the 27 member states of the European Union.
Not directly, unless it is indirectly in contact with consumers or highlights environmental commitments in its commercial communication.
Yes, if it was not already based on an audit by an independent third party and public standards: two requirements that are now essential.
Not necessarily. The directive targets sustainability labels; rating platforms follow a different logic. Opinions still differ on how certain rating systems will be treated specifically, a point to watch as the first official interpretations become clearer.
A European floor of at least 4% of annual revenue; in France, Article L. 132-2 of the Consumer Code provides for a fine of up to 10% of the revenue from the last 3 years or 50% of the related advertising expenses.
🔗 Sources :
- Directive (EU) 2024/825 of the European Parliament and of the Council of February 28, 2024
- Vivien Pertusot, The Era of Proof : communicating on environmental issues after the ECGT directive, The Meaning Machine, September 2026
- European Commission, Questions & Answers - Directive on empowering consumers for the Green Transition, June 30, 2026