EU Green Claims Directive shelved, but ECGT enforcement lands September 27

While the standalone Green Claims Directive proposal remains dormant amid political backlash, the already-adopted Empowering Consumers for the Green Transition Directive (ECGT, Directive 2024/825) becomes directly enforceable across all 27 member states on September 27, 2026, banning unsubstantiated generic claims like "eco-friendly" or "sustainable," prohibiting offset-based "carbon neutral" product claims outright, and barring self-certified sustainability labels absent recognized independent certification. Penalties reach at least 4% of a trader's annual turnover in the relevant member state, or €2 million where turnover cannot be established, with no grandfathering for products already in market channels. Marketing, compliance, and litigation counsel should be running claims audits now — mapping every consumer-facing environmental claim, including brand names and visual identity elements, against the four prohibited categories, and documenting substantiation evidence chains before the enforcement date, since national consumer protection authorities will have direct enforcement power once the deadline passes and there is no transition period.