The EU has adopted the Empowering Consumers for the Green Transition Directive (Directive 825/2024/EU) (ECGT Directive). This Directive introduces changes to existing EU consumer protection laws: the Unfair Commercial Practices Directive (Directive 2005/29/EC) and the Consumer Rights Directive (Directive 2011/83/EU). It is designed to ensure that environmental claims made to EU consumers are accurate, transparent, and independently substantiated.
EU Member States must apply the ECGT Directive from 27th September 2026.
The ECGT Directive applies to any organization making business-to-consumer (B2C) claims in the EU, or marketing products or services to EU consumers, regardless of where the organization itself is headquartered. The precise scope of the Directive will also depend on how it is transposed in different EU Member States.
Among other things, key elements of the ECGT Directive include:
On this page, we have summarised key information about changes that we are making to certification requirements under the CarbonNeutral Protocol and Climate Impact Partners Protocol, to align with our current understanding of the requirements of the ECGT Directive, and to support our clients to make high-integrity claims. This information is relevant for all companies who currently display a certification from one of these protocols or wish to do so in future.
Identify whether your company is impacted by the ECGT Directive
It is important that you identify whether your organization is required to comply with the ECGT Directive, and inform Climate Impact Partners as soon as possible if so, by contacting your account manager, and copying in the Assessments team using the address assessments@climateimpact.com.
Climate Impact Partners will attempt to contact all organizations which are currently certified or have held certification within the past 12 months to request confirmation of whether or not the organization is impacted by the ECGT Directive. However, you are solely responsible for identifying whether the ECGT Directive applies to your organization, and ensuring compliance with the Directive and other applicable laws and regulations.
Companies who are unsure as to whether they are affected by the ECGT Directive should consult with their own legal advisors. For more information about the ECGT Directive, including access to the Directive, and guidance from the European Commission on how the Directive applies to corporate sustainability reporting and disclosures, visit the European Commission’s website.
What do certified companies with obligations under the ECGT Directive need to do?
1) Transition CarbonNeutral product certification claims to Climate Impact Partners certification
The ECGT Directive bans the use of consumer-facing ‘carbon neutral’ (or similar) claims for products within the EU. This includes any CarbonNeutral product certifications.
We require Companies who are within scope of the ECGT Directive and hold CarbonNeutral product certification to transition to Climate Impact Partners certification by 27th September 2026, and to transition all related claims, assets and materials, including use of certification logos, from CarbonNeutral to Climate Impact Partners certified by that date.
The Climate Impact Partners certification has been designed to allow for a straightforward transition from CarbonNeutral certification. Read our Climate Impact Partners Protocol for more information on contribution claims.
Any organization within scope of the ECGT Directive holding a B2C CarbonNeutral product certification must remove all CarbonNeutral claims on packaging, websites, etc. before 27 September 2026.
2) Recertify in line with updated verification requirements
Climate Impact Partners has introduced a new verification process and Certification Verification Framework for all certifications under The CarbonNeutral Protocol and The Climate Impact Partners Protocol, in order to align with our understanding of what is required for a certification claim from either of these Protocols to qualify as a valid sustainability label under the ECGT Directive.
We require all companies in scope of the ECGT Directive who hold one of these certifications to obtain verification under the Verification Framework before 27th September 2026, if they wish to remain certified.
Verification will become mandatory for all companies certifying for the first time or renewing certification after 1 July 2027, regardless of whether they fall within the scope of the ECGT Directive. We are introducing this requirement, to help ensure that all certified companies are held accountable to the same standards.
How do I get verified in line with the Certification Verification Framework?
Climate Impact Partners is engaging one or more qualified and independent verifiers who undertake verifications in line with ISO 17065 or other international standards, and we are working to ensure that verifications can be completed for all impacted organizations before 27thSeptember 2026. We’re doing this to facilitate a smooth and cost-effective verification process, which can be built into your existing certification process, so there is no need to seek verification separately.
To note, companies can instead choose an alternative verifier, provided that this verifier meets the requirements of the ECGT Directive and any further requirements as set out in the Certification Verification Framework.
All verifications must be undertaken in accordance with the Certification Verification Framework.
What can I expect during the verification process?
If you nominate for Climate Impact Partners to arrange verification, during the verification process, the independent verifier will review documentation to confirm that you have met all relevant requirements of the CarbonNeutral Protocol or the Climate Impact Partners Protocol.
The verifier may raise clarifying questions or request additional supporting information as part of this review. You will be expected to respond to these queries in a timely manner to support completion of the verification.
What happens after verification is complete?
Once verification is complete and confirms that your company has met all requirements of the relevant Protocol, we will notify you that you can continue to use your CarbonNeutral or Climate Impact Partners logo. In this case, you will be able to continue to use the logo and claim until the contracted expiration date.
For future renewals of your certification, please be aware that logos and certificates will be issued only after verification is complete.
It is strongly suggested that companies start their verification process as soon as possible to ensure that it has been completed by the ECGT Directive deadline of 27th September 2026.
What happens if I don’t respond or verify by 27thSeptember 2026?
If you have compliance obligations under the ECGT Directive and do not complete the verification process and receive a renewed certification from us by the 27th September 2026, you must by that date cease all use of logos, trademarks and certification claims awarded by Climate Impact Partners. This applies across all current materials and channels, including packaging, marketing materials and websites.
Certification fees will not be refunded to companies who do not complete the verification process.
A company whose certification is not renewed by 27 September 2026, due to failure to obtain successful verification before that date, may choose to restart their certification at a later date through undertaking verification – the door to certification has not been closed to them. In the meantime, however, your certification will expire and no use of related logos will be permitted.
Is there flexibility for achieving verification?
No. Companies in scope of the ECGT Directive must obtain a verification in support of their certification, and receive confirmation of certification by Climate Impact Partners by 27th September 2026 if they wish to continue to display their certification logo.
Under Climate Impact Partner’s requirements, companies who do not need to comply with the ECGT Directive will be required to follow the new verification requirements from 1st July 2027.
While we understand that verification adds an additional step to the certification process, it helps to reinforce the integrity of the certification. Our requirement for verification not only helps meet regulatory requirements, but also makes sure all certified companies are held accountable to the same high standards and best practice.
Is the verification an additional cost?
Yes, there is a small verification fee associated with using the third-party verification body arranged by Climate Impact Partners.
However, as noted above, companies are not obligated to use Climate Impact Partner’s verification partner. See the Certification Verification Framework for more information.
I’m not based in the EU, does the ECGT Directive still apply to me?
The ECGT Directive can apply to companies regardless of where they are geographically situated. You may be impacted even if you are not based within the EU. For example, a US-based company selling products or communicating to consumers within the EU could fall within the scope of the ECGT Directive, even if it does not have any physical operations or offices outside the US.
We recommend that you consult with your own legal advisors to understand how the ECGT Directive affects you.
Could the requirements change?
We are closely monitoring ongoing development and implementation of the ECGT Directive into national laws by EU member states.
We have updated our certification requirements based on our current understanding of what is required by the ECGT Directive, but this may require further changes over time as the ECGT is implemented and enforced.
Where relevant, we will inform certified companies of any anticipated changes to our certification requirements as early as possible.
We thank all organizations using our certifications for their understanding as we navigate the changing regulatory landscape, and we remain committed to supporting companies to communicate about their certifications in a high integrity, transparent and impactful way.
Disclaimer: This webpage is for general guidance purposes only and does not constitute legal advice. Climate Impact Partners takes no responsibility for organizations’ compliance with the ECGT Directive or any other law or regulation. Whilst reasonable steps have been taken to ensure that the information contained on this webpage is correct, Climate Impact Partners makes no warranty or representation as to its accuracy and accepts no liability for any errors or omissions. The information in on this webpage may be updated from time to time without notice.
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