ECGT Checklist for SMEs (<250 Employees): Compliance in 7 Steps

Why There Is No SME Exemption

The ECGT amends the Unfair Commercial Practices Directive (UCPD 2005/29) and the Consumer Rights Directive (2011/83), both of which apply to all traders without size thresholds. Article 9 of the ECGT imposes proportionality in enforcement — penalties must be "effective, proportionate and dissuasive" — but the substantive prohibitions apply equally to any trader communicating with EU consumers.

The European Commission FAQ document (27 November 2025) confirms: "The Directive applies to all traders, regardless of size. Member States may take the size of the trader into account when setting penalties, but not when determining whether a practice is prohibited."

For a 10-employee business, the practical implication is: the same claim that triggers a €7.5 million fine for TotalEnergies will trigger a proportionate fine — but the claim still has to come down.

Source: European Commission ECGT FAQ, November 2025.

Step 1 — Inventory Every Green Claim (≈2 hours)

Export a list of every page on your website and every published marketing asset. Search each one for environmental terms. At minimum, look for:

• Product pages, landing pages, homepage, footer
• Email templates (welcome, order confirmation, newsletter)
• PDF catalogues, product data sheets, corporate brochures
• Social media bios and pinned posts
• Partner and retailer pages that describe your product

The output is a spreadsheet with three columns: URL / location, exact claim text, date of last update. Every row needs a decision by step 7.

Our free scanner completes this inventory automatically for up to 100 pages on the free tier.

Step 2 — Remove the 28 Banned Terms (≈1 hour)

The ECGT directly or indirectly prohibits 28 environmental marketing terms when used without substantiation. The core list includes "eco-friendly," "environmentally friendly," "green," "natural," "nature-friendly," "climate-friendly," "climate-neutral," "carbon-neutral," "carbon-positive," "net-zero," "biodegradable," "compostable," "sustainable," "responsible," "conscious," "eco," "gentle on the environment," and "zero emissions."

For each banned term appearing on your pages, one of three actions:

1. Delete the term entirely.
2. Replace with a specific, substantiated claim (e.g. "eco-friendly packaging" → "packaging made from 80% post-consumer recycled cardboard, certified by FSC").
3. Reserve the term for products with a third-party certification meeting the term's definition under the directive.

Full list: 28 banned green terms under the EU ECGT Directive.

Step 3 — Kill Offset-Based Neutrality Claims (≈30 minutes)

From 27 September 2026, claims of "carbon-neutral," "climate-neutral," or "net zero" based solely or primarily on offset purchases are banned outright. The directive classifies them as unfair commercial practices in Annex I point 4f.

If any of your pages say "carbon neutral shipping," "climate-neutral product," "offset with every order," or equivalent, remove these claims unless you can demonstrate:

• The emissions reduction is primarily achieved within your own value chain (not through offsets), and
• Any residual offsets meet additionality and permanence criteria verifiable by a third-party standard (e.g. Gold Standard, Verra VCS with a high rating), and
• The proportion of reductions vs offsets is disclosed adjacent to the claim.

For most SMEs without a verified reduction pathway, the pragmatic step is to delete the neutrality claim entirely.

Step 4 — Verify or Remove Self-Created Labels (≈1 hour)

The ECGT bans any sustainability label that is not based on a certification scheme established by a public authority or verified by an independent third party. This directly targets the proliferation of homemade "eco," "leaf," "green check" and similar badges that businesses design themselves.

Review every badge, seal, icon, or visual label on your product pages. For each, one of three actions:

• Keep if it is a recognized third-party certification (EU Ecolabel, FSC, MSC, GOTS, Fairtrade, B Corp, Cradle to Cradle, OEKO-TEX, Blue Angel, Nordic Swan, EU Organic).
• Apply for verification if your internal standard is strong enough to pass an external audit (costs €2,000–€10,000 depending on scheme).
• Remove if the badge is self-created and cannot be verified.

Step 5 — Rewrite Future-Tense Commitments (≈1 hour)

Phrases like "we aim to be sustainable," "our goal is net zero by 2030," "on our journey to circular," or "committed to eliminating plastic" are now regulated. Under ECGT Article 4b, a future environmental performance claim must be based on clear, objective, publicly available, verifiable commitments, with an implementation plan and independent monitoring.

For each future-tense claim, rewrite to include:

• A specific, measurable outcome
• A baseline year
• Interim milestones (2027, 2030, 2040)
• A public link to the transition plan or methodology
• The name of the independent body monitoring progress, if any

If you cannot provide all five elements, change the tense from future to present — describe what you have done rather than what you plan to do.

Step 6 — Add Evidence Links (≈2 hours)

For every environmental claim that survives steps 2–5, add an immediately accessible evidence link. The ECGT requires that substantiation be available to the average consumer at the point of the claim — not in a buried sustainability report.

Acceptable evidence links include:

• Third-party certification number with a link to the certifier's public database
• Product-level Life Cycle Assessment summary (ISO 14040/14044)
• Methodology page on your own website explaining how the figure was calculated
• Verification statement from an accredited conformity assessment body

Buried links in footer sustainability reports do not satisfy the test. The evidence must be reachable in one click from the claim itself.

Step 7 — Document the Audit (≈30 minutes)

The ECGT does not require a formal compliance dossier, but the Member State transpositions (Germany's UWG amendment in particular) allow regulators to request documentation of how a claim was substantiated. Keep a one-page record of the audit with:

• Date of audit and URL of page reviewed
• Each claim found, decision (kept / rewritten / removed), and rationale
• Evidence link added (if kept)
• Next review date (every 6 months is a reasonable cadence)

Re-run the audit every 6 months, or immediately after any new product launch or marketing campaign.