Most ECGT compliance guides describe the rules. This playbook shows the rewrite. Twenty-five marketing phrases that will fail enforcement after 27 September 2026, each paired with a compliant replacement and the specific Annex I article that applies. Pull them into your copywriter training deck or paste directly into a claim-review form.
Each "before" is adapted from real 2024–2026 marketing copy collected from scanned websites; the "after" follows the ECGT's substantiation template (specific action / quantified outcome / baseline / methodology / verification).
Group 1 — Generic Terms (Annex I point 4a)
| # | Before (banned) | After (compliant) |
|---|---|---|
| 1 | "Our eco-friendly packaging" | "Our packaging: 80% post-consumer recycled cardboard, FSC certified — license [number]" |
| 2 | "The green choice for your home" | "A-rated energy efficiency under EU Energy Label (consumes 25 kWh/year, model [X])" |
| 3 | "A sustainable fashion brand" | "GOTS-certified organic cotton for 62% of our 2025 collection; remaining 38% is BCI cotton" |
| 4 | "Natural ingredients" | "Ingredients list: 98% plant-derived, including [specific ingredients]; full declaration on product page" |
| 5 | "Environmentally responsible manufacturing" | "Our Rotterdam facility is powered by 100% renewable electricity (Guarantee of Origin no. [X]) since January 2024" |
Group 2 — Offset-Based Neutrality (Annex I point 4d)
| # | Before (banned) | After (compliant) |
|---|---|---|
| 6 | "Carbon neutral delivery on every order" | "Delivery emissions cut 38% between 2020 and 2025 via electric-vehicle fleet; residual emissions offset through Gold Standard projects (see breakdown at /climate)" |
| 7 | "Our coffee is climate-neutral" | "Per-capsule carbon footprint: 1.9 kg CO₂e (Life Cycle Assessment per ISO 14067, verified by [auditor]). Residual offsets: 0.3 kg via Verra VCS projects" |
| 8 | "Net-zero flights on all European routes" | "Per-passenger-km emissions: 73 g CO₂e (2025), down 11% from 2019 baseline (Scope 1+2, CORSIA reporting). No neutrality claim" |
| 9 | "100% carbon-offset apparel" | "Per-garment carbon footprint: 5.2 kg CO₂e (cradle-to-gate, PEF methodology). Offsets cover Scope 3 only and are disclosed separately at /transparency" |
| 10 | "Climate-positive packaging" | "Packaging made from 95% agricultural waste fibre, substitutes 2.1 kg of virgin plastic per unit. No net-positive claim asserted" |
Group 3 — Self-Created Labels (point 4c)
| # | Before (banned) | After (compliant) |
|---|---|---|
| 11 | "[Brand] Conscious Collection — our sustainable choice" | "Our Organic Line — every item GOTS certified (license [X]). See all certifications at /certified" |
| 12 | "Green Leaf badge — our internal sustainability seal" | "Products displaying the EU Ecolabel (license [X]) meet verified environmental criteria across their lifecycle" |
| 13 | "Eco Design score 8/10 on this product" | "Product Environmental Footprint study (PEF methodology) available at /pef — see climate, water, resource-use indicators" |
| 14 | "Certified by our own responsible sourcing program" | "Certified by the Roundtable on Sustainable Palm Oil (RSPO) — certificate [X], verified at rspo.org" |
| 15 | "[Brand] Planet Score: A+" | "Planet-score.org independent label: [rating], based on open methodology at planet-score.org/methodology" |
Group 4 — Scope Overstatement (point 4b)
| # | Before (banned) | After (compliant) |
|---|---|---|
| 16 | "We run on 100% renewable energy" | "Our head office and EU distribution centres run on 100% renewable electricity since 2024 (Scope 2 market-based). Manufacturing uses a separate mix — see /energy-breakdown" |
| 17 | "A recycled bottle" | "Bottle body: 80% post-consumer recycled PET. Cap and label: virgin plastic" |
| 18 | "Made from sustainable materials" | "62% of raw materials by weight from GOTS-certified organic cotton; 22% from BCI cotton; 16% from conventional polyester (2024 annual disclosure)" |
| 19 | "Our store network is zero-waste" | "98% of in-store operational waste diverted from landfill in 2024 through [specific programme]; audited by [auditor]" |
| 20 | "Our supply chain is ethical and sustainable" | "Tier 1 suppliers: 100% audited against SA8000. Tier 2: 67% audited. Tier 3: not yet audited — roadmap at /supply-chain" |
Group 5 — Future Commitments (point 4f)
| # | Before (banned) | After (compliant) |
|---|---|---|
| 21 | "Net zero by 2050" | "Science-Based Targets-validated pathway: Scope 1+2 -42% by 2030 (2019 baseline); Scope 3 -25% by 2030; net zero by 2050. Annual progress audited by [auditor] — see /sbti-report" |
| 22 | "Committed to eliminating plastic" | "Reduced virgin plastic use 31% between 2020 and 2024. Target: -60% by 2028 with quarterly progress published at /plastic-tracker" |
| 23 | "Our journey to circular" | "In 2024, 28% of products sold contained post-consumer recycled content. Interim targets: 45% by 2027, 70% by 2030 (ISO 14021 methodology)" |
Group 6 — Legal Requirement Presented as Feature
| # | Before (banned) | After (compliant) |
|---|---|---|
| 24 | "Our products are CFC-free!" | (Remove entirely — CFCs banned globally since 1987; mentioning compliance with long-standing legal requirements is a misleading practice under Annex I point 23 UCPD) |
| 25 | "BPA-free water bottles" | "Bottles made from Tritan copolyester — BPA-free and also phthalate-free, tested per EU Regulation 10/2011" (only if the "also" information is genuinely differentiating) |
Claims 24 and 25 illustrate the "irrelevance" greenwashing pattern: true but meaningless because the attribute is legally required. Under Annex I point 23 of the amended UCPD, presenting legal obligations as distinctive product features is a misleading commercial practice.
Find the Claims Your Copy Needs to Rewrite
Our free scanner flags every ECGT-banned term on any URL and outputs a PDF with the exact rewrite template for each.
Free Greenwashing ScanFrequently Asked Questions
Why are these specific rewrites compliant?
Each rewrite follows the ECGT substantiation template: specific action / quantified outcome / baseline / methodology / verification. Every compliant version identifies who verified the claim and where the evidence can be accessed, matching the directive's requirement that substantiation be reachable from the claim itself.
Can I shorten the rewrites for mobile or packaging?
Yes — the core data points can be condensed and linked. For instance, a product label can carry a QR code leading to the full methodology page. The requirement is accessibility, not length.
What if I cannot provide all five elements (action, outcome, baseline, methodology, verification)?
Rewrite the claim from future-tense to present-tense, describing what has already been achieved rather than what is planned. If even that cannot be substantiated, the safe option is to remove the claim.
Are these rewrites compliant in every EU country?
Yes, but national transpositions (e.g. Germany's UWG amendment) may add specific requirements. Rewrites aligned with the strictest transposition are compliant in every Member State.
What about social media and product listings on third-party platforms?
ECGT applies to all consumer-facing communication including Amazon, Zalando, TikTok Shop, and Instagram posts. The same rewrite rules apply regardless of where the claim appears.
Bottom Line
ECGT-compliant copy is longer, more specific, and more linked than what most brands currently publish. Treat this playbook as a pattern library: match your existing claim to the closest "before" column, adopt the "after" structure, fill in your own data, and publish. Re-audit every 6 months with our free scanner to catch new claims before they trigger enforcement.