EU anti-greenwashing law: what you need to know

Terms like ‘eco-friendly’, ‘sustainable’ and ‘biodegradable’ have long appeared on pet products, often without clear definitions or proof. From September, a new European directive will change that, allowing only claims backed by recognized ecolabels or independent verification.

Reshaping the claims landscape

The EU’s Empowering Consumers for the Green Transition (ECGT) Directive becomes enforceable on 27 September 2026. It will fundamentally reshape how environmental claims can be used in the region’s pet industry.

The ECGT ends the ambiguity of product claims. The directive bans generic environmental claims unless a company can prove “recognized excellent environmental performance”, which means an officially recognized ecolabel or equivalent independent verification. Sustainability language is no longer a creative exercise. It becomes a regulated statement that must be grounded in verifiable evidence.

For pet brands, particularly those that rely on environmental positioning, this marks a strategic shift that cannot be postponed.

Preparation: initial steps

The first step in preparing for the ECGT is to conduct a complete audit of every platform where consumers encounter your claims. It is no longer sufficient to merely review the physical packaging. The ECGT applies equally to websites, online retailers, social media channels, influencer content, trade materials and in-store communications.

This process often reveals far more environmental messaging than companies expect. Legacy web pages, outdated Amazon descriptions, influencer posts from years ago and even creative choices (green color palettes, leaves, arrows arranged to suggest circularity) may be interpreted as environmental claims. Under the ECGT, these implicit cues must be treated with the same scrutiny as explicit statements.

Review through a regulator’s lens

The goal is to re-examine your brand through the eyes of a regulator rather than a marketer. What impression does the consumer reasonably receive? Would they infer that the product has superior environmental performance? The directive is designed precisely to prevent impressions that exceed measurable reality.

One type of environmental messaging is especially risky: broad claims that imply whole-product environmental excellence when only part of the product offers any benefit (Recital 11, Directive (EU) 2024/825).

A real-world example

Imagine a pack of dog treats advertised as ‘eco-friendly’ because the pouch contains recycled plastic. Under the ECGT, this is no longer acceptable. The directive requires companies to avoid implying product-wide advantages when the environmental benefit applies only to one component. Instead of ‘eco-friendly treats’, the compliant version becomes ‘packaging made with 15% recycled LDPE’. The difference is substantial in regulatory meaning.

Precedents for enforcement

Although the ECGT will not become enforceable until later this year, many instructive precedents have already been set in Europe for how regulators assess misleading environmental claims. Several are relevant to pet products.

For instance, France’s Directorate General for Competition Policy, Consumer Affairs and Fraud Control (DGCCRF) has repeatedly examined misleading biodegradability and compostability claims across a range of consumer goods.

Its findings emphasize that claims are misleading whenever typical disposal conditions do not allow the advertised environmental benefit to occur. This principle applies directly to compostable pet waste bags, where disposal infrastructure varies widely and the claimed organic breakdown is often not supported.

Additionally, some legal actions recently emerged outside Europe concerning issues that mirror the ECGT’s logic. Investigations by American law firm Pollock Cohen have questioned whether bags marketed as ‘compostable’ or ‘environmentally friendly’ actually decompose under real consumer conditions or simply under controlled industrial tests. In several cases, products held certifications that were technically correct but irrelevant to everyday disposal practices.

A six-stage roadmap to ECGT compliance

Stage 1: claims mapping

The ECGT defines an environmental claim as “any message or representation [ … ] including labels, symbols and brand names” (Amendments to Directive 2005/29/ EC) that suggests environmental impact. Companies must therefore map all claims across packaging, websites, Amazon listings, social media, influencer scripts and trade sheets. Many pet brands will discover outdated ‘eco-friendly’ language or iconography still present in online listings.

Stage 2: claim classification

Mapped claims must be evaluated against the ECGT’s restrictions. Generic terms like ‘eco-friendly’, ‘green’ or ‘biodegradable’ cannot be used unless a product demonstrates “recognized excellent environmental performance”. This stage clarifies which claims can remain unchanged, which require precise rewording, which require evidence, and which must be eliminated. For example, a pouch labeled ‘sustainable packaging’ may need to become ‘packaging made with 50% recycled cardboard’, unless an accredited ecolabel supports the broader claim.

Stage 3: evidence collection and inventory

The directive requires evidence that is accurate, up to date and verifiable. Companies must therefore gather supplier documentation, test results, life-cycle assessments or certifications. For instance, a pet waste bag claiming compostability must demonstrate that it breaks down under realistic consumer disposal conditions, not just in industrial composting processes that consumers cannot access.

Stage 4: messaging and packaging update

With evidence in place, brands can update claims to ensure they are clear, relevant and unambiguous. This often means replacing broad adjectives with precise statements about materials, manufacturing or end-of- life pathways. Where benefits apply only to packaging, the claim must state this explicitly and without overreach.

Stage 5: team training

Marketing, design, customer service and sales teams must understand ECGT rules to avoid inadvertent non-compliance. Many instances of greenwashing arise not from deliberate misrepresentation but from well-intentioned content created without regulatory awareness.

Stage 6: internal review

To maintain compliance, companies need a structured pre-launch review process for all future environmental communication. This includes documentation procedures, approval workflows and regular updates of any claim dependent on changing suppliers, formulations or packaging.

What will the ECGT really change?

For pet industry executives, the most important shift is not theoretical scrutiny. It is how the ECGT changes three very practical aspects: which claims survive, which products you invest in and how you work with retailers.

First, not every claim is worth saving. For some stock-keeping units (SKUs), the cost and complexity of gathering evidence or securing certification will outweigh the marketing value of a generic ‘green’ tagline. Many companies will quietly retire vague claims on lower-volume or legacy products, reserving substantiated environmental language for a smaller number of ‘hero’ lines where they can genuinely demonstrate excellent performance.

Developing ECGT-native products

Second, new products will need to be ‘ECGT-native’ from day one, because it will be much harder to bolt on sustainability claims at the end of development. Formulation, packaging format, supplier choice and end-of-life design will need to be planned with evidence in mind. A new ‘compostable’ pet waste bag, for example, will have to be designed around realistic disposal scenarios, not just laboratory test conditions or marketing aspirations.

Third, retailers will expect proof, not promises. As national authorities begin to transpose the ECGT into national law by March 2026, large retail chains are likely to tighten their own requirements to avoid being associated with misleading claims on the shelf. For pet suppliers, that means environmental messaging will increasingly be part of listing negotiations and line reviews.

Having clear documentation and conservative, defensible claims will become a commercial advantage, not just a legal safeguard. The ECGT raises the bar for everyone. The brands that lead the next phase of sustainable pet care will be those that choose their claims deliberately, substantiate them rigorously and treat environmental messaging as a regulated business asset, not as a nice story to tell.

How ready is your company?

A useful way to think about the ECGT is as a very simple readiness test. By the time the directive applies, a pet company should be able to answer ‘yes’ to these three questions:

1. Do we know exactly where every environmental claim appears for every SKU?
2. Can we show credible, up-to-date evidence for the claims we’ve decided to keep?
3. Do we have a process that stops new non- compliant claims from slipping into the market?

If the answer is ‘no’ to any of these, the ECGT isn’t just a legal risk – it is a sign that your brand narrative and your environmental performance are drifting apart.

From here, the path is clear: build a single, owned inventory of all claims, decide which ones remain strategically worth defending, and create a documented route to gather the evidence you lack. Then embed cross-functional reviews so that every future piece of packaging or marketing is compliant by design, not by correction.