Green communication without greenwashing.

In short: The difference lies in the content and the timeline. Empowering Consumers is the directive you need to act on now, as it enters into force in September 2026 and sets the new framework for marketing. Green Claims concerns the technical verification behind claims and is still awaiting final adoption.

Empowering Consumers for the Green Transition (ECGT) This directive has been adopted by the EU and must be implemented into national legislation by September 27, 2026.

• Focus: The directive updates the rules on unfair commercial practices. It covers much more than just a ban on vague words like “eco-friendly.” It requires that all sustainability communication be precise, well-documented, and balanced. For example, you cannot highlight single sustainable initiatives if your company’s overall footprint pulls in the other direction, and your visuals must not promise more than the product can deliver.

• Consequence: From September, greenwashing will not just be a matter of lost credibility, but a real financial risk. Violations can lead to significant fines based on company turnover.

Green Claims Directive (GCD)

• Status: It is not the Green Claims Directive that changes marketing rules this September, even though many believe so. This directive is currently on hold, awaiting final negotiations.

• Focus: If and when Green Claims is adopted, it will act as an “overlay directive.” It will set the heavy, technical frameworks for how we must document and verify our claims (e.g., through specific Life Cycle Assessments and requirements for 3rd party approval before marketing).

• Consequence: Right now, it is a “future scenario” to keep an eye on, but it does not dictate the law in 2026.

Are you in doubt whether your current communication is legal under the upcoming tightening? Get a 360-degree communication check at Act by Choice.

The most important thing to understand is that this is no longer a distant EU vision. The directive will be implemented directly into national laws across EU member states by September 27, 2026.

The core principle can be boiled down to: “No proof, no claim.” From September 2026, greenwashing is no longer just “misleading”; it involves a real financial risk for companies in the form of lawsuits, fines, and serious damage to reputation. Going forward, you must be able to prove what you say, down to the last detail.

The new rules specifically mean that you:

• Must not use general “vague claims”: Words like “green,” “sustainable,” “eco-friendly,” or “climate-conscious” will effectively be banned as eye-catchers unless you can document an excellent environmental performance in that specific area, something very few companies can actually do. You can no longer call a product “green” simply because the packaging is made of recycled materials.

• Must have data ready before you communicate: It is not enough to dig up the numbers if someone asks. The documentation must be ready on your desk the moment the campaign launches, and it must be easily accessible to both customers and partners.

• Must not omit material information: It will be illegal to highlight a small green detail (e.g., “we use paper straws”) if your overall company or product significantly burdens the environment in other parameters. Your marketing must provide a fair picture of the overall reality, and it must be clear whether you are talking about the product or the entire company.

It sounds strict, but it is actually a huge advantage for companies that have control over their sustainability journey and documentation. It clears the market of “noise” and unserious claims, allowing your genuine efforts to stand out more clearly.

Do you have the data to back up your claims? Act by Choice help you map your initiatives and review your documentation so you are equipped to communicate without greenwashing.

Few companies greenwash on purpose. Most often, problems arise from a combination of enthusiasm for initiatives and a lack of knowledge about the details of the rules. Here are four classic traps you need to steer clear of to avoid fines and shitstorms.

1. The undefined buzzwords (Vague claims) This is the most frequent mistake. Many use words like “eco-friendly,” “green,” “natural,” or “climate-conscious” without clarifying them.

• The problem: The words are absolute. When you say “eco-friendly,” the consumer perceives it as if the product benefits the environment. But virtually all production burdens the environment.

• The solution: Be specific. Don’t write “green packaging”; write “packaging made from 100% recycled plastic.” The more specific you are, the safer you stand.

2. Visual misleading Your images and colors also count as green marketing claims.

• The problem: Using green colors, leaves, forests, or nature symbols in the marketing of a product that actually has a negative environmental impact. This creates an emotional link to nature that does not match reality.

• The solution: Ensure visual neutrality, even when your product has a documented environmental benefit. The visuals must not promise more than the product can deliver.

3. Irrelevant claims Marketing something as a special sustainable benefit if it is actually just a legal requirement or an industry standard.

• The problem: A classic example is writing “CFC-free” on a spray can (which has been a legal requirement for decades) or highlighting that you comply with environmental legislation. It makes the company appear better than competitors on a false basis.

• The solution: Only communicate about initiatives where you do more than what the law requires.

4. “The Lesser of Two Evils” (Hidden trade-offs) Highlighting a small green improvement on a product that is fundamentally environmentally damaging, without mentioning the main problem.

• The problem: Marketing a petrol car as “green” because the upholstery is made from recycled bottles. The upholstery may have a lower carbon footprint, but it doesn’t change the fact that the car emits CO2.

• The solution: Be honest about the whole picture. You are allowed to talk about the small steps, but you must not let them overshadow the overall impact.

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Are you in doubt if you are painting your company greener than it is? Act by Choice offers to screen your current website and sales material for typical pitfalls, so you can correct errors and find new ways to communicate without greenwashing