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Prohibited generic claims, no more in-house labels, penalties of up to 10% of revenue: what the ECGT will change for fashion brands starting in September 2026.
In 2025, Shein was fined 40 million euros by the DGCCRF, in particular for failing to substantiate the environmental claims posted on its website. That same year, the results of a survey of 3,000 businesses (in the textile, furniture, and cosmetics industries) revealed that more than 15% of the businesses inspected had committed serious violations.
Starting in September 2026, the transposition into French law of the European ECGT Directive (Empowering Consumers for the Green Transition, Directive 2024/825) will significantly tighten the rules: certain practices that were previously penalized on a case-by-case basis will become illegal by default.
This article breaks down what’s actually changing for fashion brands: the new scope of claims, the ban on generic descriptions, the end of in-house labels, practices now considered unfair, and a four-step method for bringing your communications into compliance.
The ECGT redefines the concept of environmental claims. It now includes:
“Any non-mandatory message or statement […], in any form whatsoever, including text, an image, a graphic representation, or a symbol such as a label, trademark, company name, or product name, in the context of a commercial communication, that asserts or implies that a product […] has a positive or neutral environmental impact, is less harmful to the environment than other products […], or has improved its environmental impact over time.”
Three major expansions compared to the previous framework:
The ECGT distinguishes between two categories.
Any environmental claim made in writing or orally that is not part of a sustainability label and for which the specifications are not provided in clear and conspicuous terms on the same medium.
The terms explicitly listed in the directive speak for themselves: environmentally friendly, nature-friendly, green, nature-friendly, ecological, good for the environment, good for the climate, environmentally beneficial, low-carbon, energy-efficient, biodegradable, and bio-based.
A generic claim ceases to be generic once it is clarified, provided that the clarification appears on the same medium, in the same advertisement, on the same packaging, or on the same online sales interface. An asterisk linking to a separate page on the website is not sufficient.
The ECGT prohibits generic claims unless the company can demonstrate excellent environmental performance relevant to the claim:
Important point: The evidence must cover the entire allegation, not just part of it.
For fashion brands whose collections do not carry the European Ecolabel, the conclusion is clear: they must either stop using generic terminology or replace it with specific, quantifiable claims.
The ECGT introduces the concept of a Sustainability Label (LDD): any voluntary trust label, quality label, or equivalent—whether public or private—that recognizes a product, process, or company for its environmental or social characteristics. Mandatory labels required by European or national law (such as energy labels or repairability indices) are excluded from this definition.
Why this focus? An impact assessment by the European Commission identified 230 environmental labels on the market, nearly half of which are awarded without adequate verification. Yet these labels carry significant weight in purchasing decisions.
From now on, the use of a private label involves a process involving three distinct parties:
The ECGT also requires that the specifications be made public and non-discriminatory, that a withdrawal procedure be in place in the event of non-compliance, and that the third-party organization be independent of both the brand and the label owner.
The ECGT amends Directive 2005/29/EC on unfair commercial practices. Placing a practice on the list of “unfair practices in all circumstances” is tantamount tobanning it outright: it will no longer be necessary to prove that the consumer’s behavior was influenced.
Among the practices that are now prohibited by default:
Two other practices are still evaluated on a case-by-case basis, but are now explicitly considered misleading:
Failure to comply with these rules constitutes a deceptive business practice, punishable by:
The judge may set the fine at 10 percent of the average annual revenue (calculated based on the last three known fiscal years), or at 50 percent of the expenses incurred for the advertising in question, and up to 80 percent when the deceptive practice is based on environmental claims.
In terms of inspections, the trend is clear. The 2023–2024 DGCCRF investigation covered 3,000 establishments and resulted in 430 compliance orders, more than 70 administrative fines and criminal citations, and more than 500 warnings. By comparison, the 2021–2022 investigation covered 1,100 establishments and resulted in 114 compliance orders.
The textile sector is directly targeted. One case highlighted by the investigation: the use of the term “upcycled,” accompanied by a green logo, on T-shirts and pants that were in fact imported brand-new from Asia—a violation that resulted in a criminal citation. The investigation also highlights institutional claims and brand names with environmental connotations that falsely imply that the entire product line meets certain environmental standards.
For 2025 and 2026, the DGCCRF has announced that it will step up its inspections, in cooperation with ADEME, to better target investigations into environmental claims and labeling in the textile industry.
Compile a list of all claims currently in circulation, as broadly defined by the ECGT: product descriptions, product line names, pictograms, in-house ratings, wholesale sales pitches, social media content, the “Commitments” page on the website, and the annual report. The list is almost always longer than expected.
For each claim, there are three possible outcomes:
A specific claim is only valid if the data supporting it is robust and traceable. “–30% CO₂e emissions for these jeans compared to our 2022 baseline” requires a product-level life cycle assessment (LCA), an explicit basis for comparison, and a method that is available for review.
Legal risk most often arises from a disconnect between the marketing and CSR teams. Three simple safeguards:
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