Carbon Labelling Regulations 2026–2027: The Complete EU Roadmap

Master Timeline 2026–2027

Primary sources consolidated below in each section.

ECGT Directive — 27 September 2026

The ECGT Directive (2024/825) is the umbrella regime for all consumer-facing environmental claims. It does not prescribe carbon labels; it regulates the words and symbols that can appear alongside them. From 27 September 2026:

• Generic terms ("climate-friendly," "carbon-smart," "climate-neutral") are banned unless based on recognized excellence in environmental performance.
• Self-created sustainability labels are banned unless based on a certification scheme or established by a public authority.
• Claims of "neutral," "reduced," or "positive impact" based solely on greenhouse-gas offsetting are prohibited.

Source: Directive (EU) 2024/825 — EUR-Lex. Full transposition status in our country tracker.

CBAM Certificates — 1 February 2027

The Carbon Border Adjustment Mechanism (CBAM) is the EU's import-side carbon pricing instrument. The timeline was revised in October 2025 under the Omnibus simplification package:

• Transitional reporting phase from October 2023 continues until end-2025 (quarterly reports on embedded emissions).
• 1 February 2027 — certificate sales open. Declarants buy certificates for 2026 embedded emissions in covered imports.
• Single 50-tonne cumulative threshold exempts small importers (introduced October 2025).
• Annual CBAM declaration due by 30 September of the following year (previously 31 May).
• Default value markups: 10% in 2026, 20% in 2027, 30% from 2028 onward.
• Certificate pricing: quarterly average of EU ETS auction prices in 2026, weekly average from 2027.

Source: ICAP — CBAM simplifications and European Commission CBAM page.

Digital Product Passport — 19 July 2026 Registry, Waves 2027

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) introduces Digital Product Passports (DPPs) for a progressively expanding scope of product categories. Timeline:

• 19 July 2026 — the EU-wide DPP Registry goes live.
• 2026 — delegated act adoption for Iron & Steel.
• February 2027 — first mandatory DPP: electric vehicle batteries (via the Batteries Regulation).
• Mid-2027 — textiles and apparel delegated act application date.
• 2027 — delegated acts adopted for tyres and aluminium.
• 2027–2030 — progressive rollout: electronics, furniture, chemicals, detergents.

Products sold without a compliant DPP from their mandatory date face CE-marking denial and market exclusion. For carbon-specific disclosures, the DPP contains a mandatory carbon-footprint field for in-scope products.

Source: European Commission — Implementing ESPR.

Battery Carbon Footprint — February 2026 and 2027

The Batteries Regulation (Regulation (EU) 2023/1542) phases in carbon-footprint declarations ahead of the ESPR DPP rollout. Declaration dates:

• 18 February 2025 — electric vehicle batteries (now in force).
• 18 February 2026 — rechargeable industrial batteries >2 kWh (except those with external storage).
• 18 August 2028 — light means of transport (LMT) batteries.
• 18 August 2030 — industrial batteries with external storage.

Each declaration must be prepared per battery model per manufacturing plant, following the Product Environmental Footprint (PEF) methodology. From February 2027, EV batteries require the full digital passport, which incorporates the carbon-footprint declaration plus additional material and durability fields.

ESRS E1 Climate Disclosures — 2026 Reporting Year

The European Sustainability Reporting Standards (ESRS), under the Corporate Sustainability Reporting Directive (CSRD), require in-scope entities to publish standardized climate disclosures. The climate standard is ESRS E1. For the 2026 reporting year (first reports published in 2027):

• Scope 1, 2, and material Scope 3 emissions must be disclosed with methodology.
• Transition plan required for alignment with the Paris Agreement 1.5°C pathway.
• Carbon removals and offsets must be reported separately from gross emissions reductions.
• Interim targets (2030 / 2035 / 2040) required alongside long-term (2050) commitments.

The overlap with the ECGT is significant: ESRS E1 sets the disclosure floor, and the ECGT ensures that any public-facing communication about those disclosures is substantiated.

How the Five Regimes Interact

1. Data consistency. The carbon-footprint figure published in the battery DPP, the CBAM embedded-emissions declaration, and the ESRS E1 Scope 3 figure must be internally consistent. Divergence between regimes is an enforcement vector.
2. Substantiation layering. A marketing claim about a product's carbon footprint must match the DPP value, be backed by an ISO 14067 or PEF study, and not use ECGT-banned terms. Any single weak link triggers ECGT enforcement.
3. Single source of truth. Companies in scope of multiple regimes are standing up unified "sustainability data layers" — a single internal product-emissions database feeds the DPP, the CBAM declaration, the ESRS disclosure, and the marketing page simultaneously.
4. Enforcement overlap. The ECGT is enforced by national consumer authorities (DGCCRF, ACM, AGCM). The CBAM by national competent authorities and customs. The CSRD / ESRS by national auditors and capital-market authorities. A single misleading carbon figure can trigger parallel investigations in all three channels.