EU greenwashing ban: six things nutraceutical brands must check

The ECGT Directive now bans generic "eco-friendly" and offset-based climate claims, putting supplement labels, websites and ingredient marketing under tougher scrutiny

The EU's Empowering Consumers for the Green Transition (ECGT) Directive (formally Directive (EU) 2024/825) came into force on the 27th September this year.

For nutraceutical companies, where "clean", "natural" and "planet-friendly" tend to be marketing staples, the rules are a prompt to audit every consumer-facing sustainability claim, or risk a hefty consequence.

What is the ECGT Directive?

The ECGT Directive amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. It does this to curb greenwashing by enforcing strict rules on environmental marketing.1

It applies to any organisation making business-to-consumer claims in the EU, regardless of where it is headquartered. A US or an Asian ingredient brand selling supplements to EU shoppers is therefore in scope.

What is now banned?

Four changes matter most for the sector:

  1. Generic claims: terms such as "green," "carbon friendly" and "environmentally friendly" count as generic claims in themselves, unless they sit within a certified sustainability label or rules set by a public authority4
  2. Offset-based climate claims: claims that a product has a neutral, reduced or positive greenhouse gas impact are prohibited when they rely on carbon offsetting
  3. Self-created labels: self-created certification schemes and unverifiable labels are prohibited
  4. Unverified future promises: claims about future environmental performance must be verified by an independent third-party expert.

Why nutraceuticals are exposed

Sustainability messaging is now routine in the supplement aisle: regenerative sourcing, plastic-free pouches, "carbon-neutral" shipping, "clean" formulations.

Brands that rely on vague virtue terms, or on in-house leaf icons, are the most likely to be caught out.

The ECGT is separate from the rules on nutrition and health claims — Regulation (EC) No 1924/2006 still governs health claims on food supplements and requires scientific substantiation and authorisation.6

Companies now have two compliance tracks and passing one doesn't satisfy the other. Any use of "natural," in an environmental sense, probably deserves a fresh legal check.

Additionally, stock that is already on shelves is not exempt. These updated rules also reach products and packaging manufactured, ordered or already on retailers' shelves before the application date — though authorities may take a phased, proportionate approach to enforcement early on.3,5

Retailers selling non-compliant products could also be fined. That makes supplier and distributor copy a live risk. 

Enforcement will vary by country. The Commission has noted that transposition into national law was still ongoing as the application date approached.1

Under earlier EU consumer-law reforms, maximum fines for widespread cross-border infringements must be at least 4% of annual turnover in the affected Member States.

In Italy, for example, the new rules extend multi-million-euro penalties to environmental and social performance information. 

What companies should do now

  1. Audit every claim: cover packaging, product pages, social posts, email flows, sell sheets and retailer data feeds. Prioritise templates and banners that repeat across many pages
  2. Remove or substantiate generic terms: replace "eco-friendly" with specific, measurable facts, such as the recycled content of a pouch or the percentage of renewable energy used in manufacturing
  3. Review climate claims: drop product-level "carbon neutral" language that depends on offsets. Certification bodies are adjusting too: Climate Impact Partners requires in-scope companies holding CarbonNeutral product certification to move to its new certification and update all related claims, assets and logos2
  4. Check your badges: keep only labels backed by an independent, recognised certification scheme
  5. Back up any roadmap: publish an implementation plan with independent verification before promoting future targets
  6. Brief suppliers and retailers: make sure ingredient partners' marketing copy doesn't carry non-compliant claims into your channels.

Don't wait on Brussels' other proposal

Some firms hoped the withdrawn Green Claims Directive would soften the regime. Its withdrawal does not, however, affect the ECGT, which is already law. 

For nutraceutical brands, the safest approach is simple: say less, prove more and keep the evidence on file.

References

  1. https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_en?filename=faq-empowerting-consumers-gtd.pdf
  2. https://www.climateimpact.com/ecgt-directive/
  3. https://www.carbontrust.com/news-and-insights/insights/ecgt-directive-explained-what-organisations-who-sell-in-europe-should-know-and-do
  4. https://www.arbor.eco/blog/eu-ecgt-empowering-consumers-for-the-green-transition-directive
  5. https://coslaw.eu/directive-eu-2024-825-generic-environmental-claims-and-practices-banned-in-the-eu-from-27-september-2026/
  6. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC12841469/

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