Empowering Consumers for the Green Transition: what the ECGT Directive means for Belgian businesses and consumers

Adopted on 28 February 2024, the ECGT Directive strengthens existing EU consumer protection rules to combat misleading sustainability claims and ensure that information provided to consumers is accurate, transparent and verifiable. The Directive had to be transposed into Belgian law by 27 March 2026, with application from 27 September 2026.

As of April 2026, Belgium has not yet adopted the required transposition legislation. A legislative proposal (Parl. Doc. 56K0224), introduced in 2024, remains pending.

1. Goal: A strengthened consumer protection framework

The ECGT Directive does not introduce a standalone sustainability regime but clarifies how existing consumer protection rules apply to sustainability claims. Its objective is to ensure that such claims are no longer used as vague marketing concepts, but can be assessed against enforceable legal standards.

2. Scope of application

The Directive applies in a business-to-consumer (B2C) context and does not cover purely consumer-to-consumer (C2C) relationships. It protects consumers, meaning natural persons acting outside their trade or profession, against misleading commercial practices.

Its material scope is broad and covers both environmental and social characteristics of goods and services.

In particular, it addresses:

• general environmental claims such as “green”, “eco-friendly” or “sustainable”;
• claims relating to ethical sourcing or socially responsible production;
• claims concerning future environmental performance, including climate neutrality or net-zero targets;
• sustainability labels and certification schemes;
• information on product durability, reparability and lifespan.

3. Substantiation of sustainability claims

The ECGT Directive introduces stricter requirements on how sustainability claims must be formulated and substantiated.

In practice, this means that statements such as “climate-neutral”, “CO₂ compensated” or “ethically produced” must be sufficiently specific and supported by evidence. Claims may not merely reflect compliance with legal requirements or rely on vague or unverified statements.

Importantly, the burden of proof lies with the trader. Companies must be able to demonstrate, based on appropriate documentation such as reports, studies, lifecycle analyses or certification evidence, that their claims correspond to reality.

The Directive also targets practices related to product durability and obsolescence. It addresses in particular:

• presenting legally required product characteristics as exceptional sustainability advantages;
• making misleading claims about product lifespan;
• failing to inform consumers about limitations to repairability;
• misleading information relating to software updates that negatively affect product performance;
• practices linked to premature obsolescence.

4. When will the ECGT Directive apply?

As of April 2026, no implementing legislation has yet been adopted in Belgium, and the legislative proposal currently remains pending.

In the absence of transposition, existing Belgian rules on unfair commercial practices will continue to apply. However, courts and authorities will, as far as possible, interpret these rules in line with the Directive. Full legal certainty will only arise once the implementing legislation enters into force.

5. Impact on businesses and consumers

The Directive applies to all companies communicating sustainability claims to consumers, regardless of size or sector. Any such claim made in advertising, packaging or digital channels may fall within its scope.

For businesses, this requires a more structured and evidence-based approach to sustainability communication. In particular, companies should:

• review marketing materials for vague or generic claims;
• substantiate climate-related statements and offsetting mechanisms;
• ensure that ethical and social claims are supported by verifiable data;
• assess product durability, repairability and software practices;
• implement internal validation processes before publishing claims.

For consumers, the Directive aims to improve trust and transparency. It enables more informed purchasing decisions by ensuring that sustainability claims are reliable, comparable and reflective of actual practices.

6. Looking ahead

The actual impact for businesses and consumers will depend on how the ECGT Directive is transposed and enforced in Belgium, as well as on its interaction with other EU initiatives, such as the proposed Green Claims Directive.

Companies should already review their sustainability communications and ensure that all claims are clear, accurate and properly substantiated. Strengthening internal controls and aligning messaging with reliable data will be key to mitigating legal risks and maintaining consumer trust. At Andersen in Belgium, we are ready to support clients throughout this process, helping to align sustainability communications with regulatory requirements and reliable data.