Directive (EU) 2024/825 on Empowering Consumers for the Green Transition (ECGT)

Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information (Text with EEA relevance).

Executive summary

Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amends Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights. Its purpose is to strengthen consumer protection against commercial practices that can hinder the green transition and to improve pre-contractual information on the durability and reparability of goods.

Among other measures, the Directive introduces new rules on environmental claims, sustainability labels, future environmental commitments, product comparisons, premature obsolescence, software updates, reparability and guarantees. Member States had to adopt and publish the national transposition measures by 27 March 2026 at the latest and apply them from 27 September 2026.

The Directive does not provide an exhaustive regulation of every environmental claim and does not replace applicable sectoral rules. Its application must be coordinated, in particular, with Regulation (EU) 2024/1781 on ecodesign for sustainable products, Directive (EU) 2024/1799 on common rules promoting the repair of goods, and other relevant Union and national rules.

Nature and scope

The Directive preserves the horizontal character of Directives 2005/29/EC and 2011/83/EU. Its rules apply mainly to commercial practices directed at consumers, that is, to B2C relationships. The analysis must be carried out by reference to the specific commercial practice, the product or service concerned, the average consumer and the applicable sectoral rules.

The Directive relies on Article 114 of the Treaty on the Functioning of the European Union as its legal basis. The information obligations and the prohibitions on unfair practices should not be confused with the corporate reporting obligations set out in rules such as Directive (EU) 2022/2464 (CSRD). That said, corporate communication that is used or reproduced as commercial communication directed at consumers can fall within the scope of the rules on unfair commercial practices.

Timeline and deadlines

Amendments to Directive 2005/29/EC, known as the Unfair Commercial Practices Directive (UCPD)

Key concepts

• Environmental claim: a message or representation, not required under Union or national law, that states, suggests or implies that a product, product category, brand or trader has a positive or no impact on the environment, is less damaging than other products, or has improved its impact over time.
• Generic environmental claim: a written or oral claim, including a claim made through audiovisual media, that does not appear on a sustainability label and for which the specification of the claim is not provided in clear and prominent terms on the same medium.
• Sustainability label: a trust mark, quality mark or equivalent, whether public or private, in the form of a sign or logo, aiming to highlight and promote the environmental or social characteristics of a product, product category, brand or trader.
• Certification scheme: a third-party verification scheme that allows a sustainability label to be granted according to public, transparent and independent requirements, developed by the scheme owner and subject to independent monitoring.

Misleading practices and omissions

The Directive extends the legal relevance of environmental and social characteristics and of circularity aspects such as durability, reparability and recyclability. The new rules are integrated into the analysis of misleading practices under Articles 6 and 7 of Directive 2005/29/EC, so a case-by-case assessment is required in these situations.

• Claims about future environmental performance: these can be misleading when based on future commitments unless the trader can demonstrate clear, objective and verifiable commitments, measurable targets, a detailed and realistic implementation plan, adequate resources, and periodic verification by an independent third-party expert free of conflicts of interest.
• Irrelevant benefits: presenting as an advantage a feature that does not derive from the function of the product or from the trader's activity can be misleading. Claiming that a product is "gluten free" would be an example when that characteristic has no relevance to the advertised product.
• Product comparisons: where comparison tools or services are used, failing to provide relevant information about the comparison method, the products and providers compared, and the measures taken to keep the information up to date can amount to a misleading omission.

Practices added to Annex I

Annex I to Directive 2005/29/EC lists practices considered unfair in all circumstances. Even so, the specific facts must be checked against the statutory description of the practice.

Amendments to Directive 2011/83/EU (Consumers Rights Directive)

The Directive strengthens the pre-contractual information that must be given to consumers, particularly in distance and off-premises contracts and in relation to goods with digital elements.

• Harmonised notice on the legal guarantee of conformity: the trader must provide a harmonised notice reminding consumers of the legal guarantee of conformity and its main features. The general minimum two-year protection derives from the Union framework, without prejudice to more favourable national periods.
• Harmonised label for commercial guarantees of durability: where the producer offers, at no additional cost to the consumer, a commercial guarantee of durability covering the entire good for a period of more than two years, the trader must provide this information through the corresponding harmonised label. The GARAN label is currently governed by Implementing Regulation (EU) 2025/1960 and applies from 27 September 2026.
• Reparability: where an applicable reparability index exists, the corresponding information must be provided. Where required under Union law, information on repair, spare parts, instructions and relevant conditions must also be provided. This Directive does not create a universal obligation to provide all such information for any product lacking a reparability index.
• Updates: for goods with digital elements and other digital content or services within the scope of the Directive, consumers must be informed, where applicable, of the period during which updates will be provided. This information obligation towards the consumer is mainly channelled through the trader, without prejudice to information that must be provided by the producer or supplier.

Practical application

Case-by-case assessment

The amendments to Articles 6 and 7 of Directive 2005/29/EC are applied by assessing the overall circumstances of the commercial practice, including its ability to materially distort the economic behaviour of the average consumer. The general framework of Articles 5 to 9 continues to apply.

Annex I practices

Practices added to Annex I are considered unfair in all circumstances when the elements described in the corresponding prohibition are met. The same materiality assessment required for a practice governed solely by Articles 6 or 7 does not apply, but the existence and scope of the conduct must still be correctly established.

Products already manufactured

The Directive sets the date from which the national measures apply, but it does not contain a general rule requiring the automatic withdrawal or relabelling of stock manufactured or placed on the market before 27 September 2026. That said, the national consumer protection authorities of the CPC Network adopted a Common Understanding in June 2026 confirming that the new rules apply to existing stock and providing for a proportionate and gradual approach during the initial phases of application, taking into account factors such as packaging cycles, stock volumes, product shelf life and the technical feasibility of corrective measures. The consequences for products, packaging, advertising and pre-existing stock must be determined under the applicable national transposition legislation, any applicable transitional provisions, and the date on which the commercial practice takes place.

Relationship to other rules

Directive (EU) 2024/825 operates as a horizontal consumer protection framework. It must be applied together with other relevant Union and national sectoral rules, including:

• Regulation (EU) 2024/1781, establishing a framework for setting ecodesign requirements for sustainable products.
• Directive (EU) 2024/1799, on common rules promoting the repair of goods.
• Regulation (EU) 2025/1960, on the harmonised label for the commercial guarantee of durability, applicable from 27 September 2026.
• Directive (EU) 2022/2464 and its national transposition rules on corporate sustainability reporting, without prejudice to corporate communication becoming subject to the rules on unfair commercial practices when used as commercial communication directed at consumers.

Conclusion

Directive (EU) 2024/825 tightens the control of environmental claims and strengthens information on durability, reparability, guarantees and updates. Its application requires distinguishing between practices subject to case-by-case assessment and practices listed in Annex I to Directive 2005/29/EC, as well as separating the trader's information obligations from the informational responsibilities of the producer or supplier. For a definitive legal publication, this text should be supplemented with a check of the applicable national transposition legislation and any guidance or implementing act in force on the date of publication.

Sources and references

1. Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 (OJ L, 2024/825, 6.3.2024). Available at: eur-lex.europa.eu/eli/dir/2024/825/oj
2. Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices (OJ L 149, 11.6.2005, p. 22). Consolidated text available at: eur-lex.europa.eu/eli/dir/2005/29
3. Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights (OJ L 304, 22.11.2011, p. 64). Consolidated text available at: eur-lex.europa.eu/eli/dir/2011/83
4. Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025 on the design and content of the harmonised notice and the harmonised label (OJ L, 2025/1960, 2.10.2025). Available at: eur-lex.europa.eu/eli/reg_impl/2025/1960/oj
5. European Commission, DG Justice and Consumers, Questions & Answers on Directive (EU) 2024/825 (June 2026). Available at: commission.europa.eu/topics/consumers/consumer-rights-and-complaints/sustainable-consumption_en
6. Common Understanding of the CPC Network authorities on old stock situations (June 2026). Available at: commission.europa.eu/.../sustainable-consumption-actions_en
7. Regulation (EU) 2024/1781, on ecodesign for sustainable products (OJ L, 2024/1781, 28.6.2024).
8. Directive (EU) 2024/1799, on common rules promoting the repair of goods (OJ L, 2024/1799, 18.7.2024).