About the ECGT/EmpCo Directive

Directive (EU) 2024/825
What is EmpCo/ECGT

What is the Empowering Consumers for the Green Transition Directive?

ECGT/EmpCo Directive

Directive (EU) 2024/825, known as the Directive (EU) 2024/825, known as the EmpCo Directive or Empowering Consumers for the Green Transition (ECGT) Directive, strengthens EU consumer protection rules, strengthens EU consumer protection rules against misleading commercial practices. It amends existing EU consumer law to address greenwashing and unclear sustainability communication, including the use of environmental and social claims and sustainability labels on consumer products such as textiles, apparel and leather goods.

The Directive does not approve or certify products or certification schemes. Instead, it sets conditions under which sustainability claims and labels may be used, especially in business-to-consumer (B2C) communications in the EU.

Who is Affected

Who must comply with the ECGT/EmpCo directive?

Anyone selling to consumers in the EU

The Directive applies to business-to-consumer commercial practices in the EU. This means:

  • EU-based companies marketing products to EU consumers
  • Non-EU companies, whose products are marketed to EU consumers directly or via EU retailers

If sustainability claims or labels are used in EU-facing marketing, packaging or online communications, these rules are relevant.

Regulated Criteria

What does the Directive regulate?

Environmental and Social Claims

Directive (EU) 2024/825 expands the list of product characteristics in the Unfair Commercial Practices Directive (UCPD 2005/29/EC) that must not mislead consumers. This includes claims and information related to:

  • Environmental performance (e.g. chemical safety, recycled content, resource use)
  • Social responsibility (e.g. responsible production, working conditions)
  • Product durability and circularity (e.g. durability, repairability, longevity, recyclability)
  • Use of sustainability labels, certification marks and trust badges

Generic or vague environmental claims such as "eco-friendly" or "sustainable" may be considered misleading unless they are clearly substantiated and explained.

Timing & Enforcement

When and how will the ECGT/EmpCo be enforced?

National authorities begin enforcing the rules in September 2026.
  • March 27, 2026: Deadline for EU Member States to transpose Directive (EU) 2024/825 into national law
  • September 27, 2026: Rules in effect
  • Enforcement by national consumer protection authorities, with penalties defined at Member State level

How OEKO-TEX® Relates to the Directive

Independence & Transparency

Independently Verified and Transparent Claims

Directive (EU) 2024/825 requires that sustainability labels used in consumer communications are based on credible, transparent and independently monitored schemes. Key requirements include:

  • Independent third-party verification
  • Objective and transparent criteria
  • Competent testing and certification organizations
  • Ongoing monitoring without conflicts of interest

OEKO-TEX® meets these requirements through its governance structure, third party testing framework and accreditation model. When the labels are used correctly and only for the products they actually cover, OEKO-TEX® supports EmpCo/ECGT-compliant sustainability claims.

2026 Updates

Independence, Formalized in 2026

Starting September 27, 2026, sustainability labels in the EU must be based on independently verified certification schemes. OEKO-TEX® has always operated with these principles. Now it's formal and demonstrable.

  • OEKO-TEX® converted from a GmbH to a corporation (AG), with a Board of Directors as the highest decision-maker
  • A Statute of Independence and an Independence Council make existing safeguards binding
  • An anonymous whistleblowing channel continues to give anyone a way to raise concerns
  • The accreditation agreement follows ISO/IEC 17065, and the certification bodies remain ISO/IEC 17025 accredited

See OEKO-TEX® Press Release

3rd-Party Monitoring

Independence and Verification

A core requirement of the Directive is that sustainability labels are not influenced by commercial interests.

  • OEKO-TEX® is a legally separate entity from the authorized testing institutes (like Hohenstein) and conformity assessment bodies
  • Authorized OEKO-TEX® institutes conduct testing and certification activities independently
  • These institutes are ISO/IEC 17025 accredited, which supports technical competence and the impartiality of laboratory activities

The OEKO-TEX® structure aligns with the Directive’s requirement for objective, third-party monitoring of certifications.

What This Means for Brands

For brands and retailers marketing textile products to EU consumers:

  • Sustainability claims and labels must be accurate, specific and verifiable
  • Claims must remain within the scope of the certification or test data
  • Generic environmental claims without clear substantiation carry increased regulatory risk
  • Sustainability labels should be based on credible, independently monitored certification programs
  • Follow the OEKO-TEX® Labeling Guide and your label claims stay EmpCo compliant

OEKO-TEX® certifications provide independent, third-party verification that brands can rely on when communicating specific product attributes. That is why OEKO-TEX® has strict, long-established rules for the use of its labels and claims, supported by clear labeling and communication guidance. Brands and retailers are responsible for ensuring that claims accurately reflect both the certification scope and the product itself.

Verified Product Claims and Informed Decisions

Independent Testing and Verification

The role of independent verification is to generate reliable data that brands can use to communicate accurately and in line with applicable regulatory and customer requirements.

Hohenstein provides independent testing, certification and technical expertise. Our data, test reports, certificates and labels support verified product claims and help ensure that sustainability communication is grounded in objective, third-party evidence.

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FAQ: OEKO-TEX® and the Empowering Consumers for the Green Transition Directive

Does Directive (EU) 2024/825 apply to companies outside of the EU?
Yes. If products are marketed to EU consumers, directly or via EU retailers, the Directive can apply to the claims and labels used in EU-facing communications.

Can OEKO-TEX® labels still be used in EU marketing?
Yes, without restriction, including after the EmpCo Directive takes effect on September 27, 2026. OEKO-TEX® labels remain legally compliant. Use them in line with their defined scope and the OEKO-TEX® Labeling Guide.

Does anything change for certified companies?
Nothing changes in daily operations. Testing, auditing and certification continue as before. The only 2026 change is stronger proof of the system's independence.

Where do I find approved wording for label claims?
The OEKO-TEX® Labeling Guide includes approved wording for websites, product pages and packaging. Follow it and your label claims stay within the certified scope.

Does OEKO-TEX® certification make a product compliant with the Directive?
OEKO-TEX® certification can support compliance by providing independent, third-party verification of specific product attributes. Brands remain responsible for ensuring that all claims are accurate and used correctly.

Are generic claims like "eco-friendly" still allowed?
Generic environmental claims may be considered misleading unless they are clearly substantiated and explained. Using specific, verified claims is lower risk.

Does the Directive cover social claims?
Yes. Directive (EU) 2024/825 also covers social claims, such as statements about working conditions or responsible production.

Does the Directive cover durability claims?
Yes, if durability is mentioned in connection with an environmental claim (e.g. "durability saves resources").

Is this the same as the Green Claims Directive?
No. Directive (EU) 2024/825 is adopted law and its national rules apply from September 27, 2026. The Green Claims Directive is a separate proposal. Negotiations stalled in 2025 after the European Commission signaled it would withdraw the proposal, and it remains pending.

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Ben Mead

Managing Director
Hohenstein Americas