Environmental Claims: How the ECGT Is Changing Things for Fashion Brands

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.

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1. An environmental claim is broader than you might think

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.”

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Three major expansions compared to the previous framework:

• The form doesn’t matter. A visual, a leaf icon, a palette of greens, a custom badge—all of these constitute a claim. This includes a brand name or the name of a product line. A line called “Eco” or “Conscious” is an environmental claim in its own right and must be substantiated as such.
• This applies to all media. Whereas the AGEC law focused primarily on the product and its packaging, the ECGT covers all forms of commercial communication: e-commerce sites, product descriptions, social media campaigns, in-store displays, brand reports, and video ads.
• B2B as well. The regulations also apply to commercial practices between businesses. Brands that sell wholesale, manufacturers, and material suppliers are all covered.

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2. Generic claims are prohibited by default

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The ECGT distinguishes between two categories.

Generic claim

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.

Specific Allegation

A generic claim ceases to be generic once it is qualified—provided that the qualification appears on the same medium, in the same commercial, on the same packaging, or on the same online sales interface. An asterisk linking to a separate page on the website is not sufficient.

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The only three exits

The ECGT prohibits generic claims unless the company can demonstrate excellent environmental performance related to the claim. There are three—and only three—ways to do this:

1. The product has been awarded the European Ecolabel.
2. The product has been awarded a Type I environmental label (ISO 14024) that is officially recognized in the member states—including the Nordic Ecolabel, Blue Angel, Österreichisches Umweltzeichen, and NL Milieukeur, among others.
3. The product falls under another provision of EU law (highest energy-efficiency label class, organic certification, etc.).

Key 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.

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3. End of in-house labels

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.

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4. What Constitutes Unfair Practices Under Any Circumstances

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:

• Generic claims not backed by recognized, outstanding environmental performance.
• Sustainability labels that are not based on a certification system or established by public authorities.
• Claims that apply to an entire product or the company when they actually pertain to only one aspect —typically, promoting the entire brand based on a collection of 12 organic cotton items.
• Claims of carbon neutrality based on offsetting. The claim must be based on the actual carbon footprint of the product and its value chain, not on external credits. A T-shirt that is “carbon neutral” thanks to a reforestation project is no longer justifiable.
• Presenting a requirement imposed by law as a distinctive advantage —for example, highlighting traceability labeling, which is already mandatory under the AGEC Act.

Two other practices are still evaluated on a case-by-case basis, but are now explicitly considered misleading:

• Future environmental commitments that are not backed by clear, verifiable, publicly available targets and are not incorporated into a detailed and realistic implementation plan. Announcing “a 50% reduction in emissions by 2030” without a documented pathway leaves the country directly exposed.
• Product comparisons based on environmental characteristics without disclosing the comparison method, the products being compared, their suppliers, and how the data is updated.

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5. Deterrent penalties and stricter controls

Failure to comply with these rules constitutes a deceptive business practice, punishable by:

• 2 years in prison
• A €300,000 fine for an individual
• €1,500,000 for a legal entity

The judge may set the fine at 10 percent of 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 involves 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.

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6. How to Prepare: A Four-Step Method

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Step 1: Map the Current Situation

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.

Step 2: Sort

For each claim, there are three possible outcomes:

1. Remove — generic claims not covered by an eco-label, uncertified in-house labels, and carbon neutrality achieved through offsetting.
2. Specify — replace the vague statement with precise, sourced information displayed on the same medium.
3. "Preserve " — a claim already supported by documented evidence that is proportionate to its scope.

Step 3: Document Using Data

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.

That is precisely the role of a platform like Waro: to measure environmental impact product by product and line by line, based on actual supply chain data, so that every published claim is backed by a verifiable calculation. A brand that compares its products must also be able to publish its methodology and how it is updated—an explicit requirement of the ECGT.

Step 4: Establish a Governance Framework

Legal risk most often arises from a disconnect between the marketing and CSR teams. Three simple safeguards:

• A validation principle: no environmental claims are published without documented and cited evidence.
• A shared database of authorized, prohibited, and conditional formulations.
• A periodic review of online claims, as both data and regulations evolve.

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