Greenwashing Deadline Six Months Away

The new European Union Directive 2024/825 on ‘Empowering Consumers for the Green Transition’ (ECGT Directive) will start to apply from September 27, 2026. It amends existing EU consumer laws and imposes new consumer information requirements that will require website changes for traders selling to EU customers. It also introduces stricter rules on claims that will impact the way traders can talk about their sustainability credentials.

It means that from September 27, 2026 onwards, all sustainability labels used in the EU must either be established by a public authority or based on a certification scheme that complies with the ECGT Directive’s requirements. If this is not the case, the sustainability labels can no longer be used by traders in the EU. Certification schemes underpinning sustainability labels need to meet requirements on transparency, openness and credibility and the trader’s compliance with the certification scheme’s standards must be verified by a third party that is independent from both the scheme owner and the trader.
Of course, these rules will be applicable in Hungary too. On September 27, an amendment to Hungarian law will take effect, establishing clearer guidelines for what businesses can communicate regarding the environmental impact of their products and services. This leaves companies with just six months to review their advertisements, packaging and online platforms.
Those who fail to prepare in time can expect significant consumer protection fines, warn experts at the international law firm Taylor Wessing, quoted by the business portal portfolio.hu.

Stricter and more uniform framework
The terms ‘eco-friendly’, ‘green’ or ‘climate-neutral’ are appearing more and more frequently on product packaging, in advertisements and in ESG communications – but the EU legislator is now establishing a stricter and more uniform framework for determining when these claims are substantiated and when they are considered misleading.
The deadline for transposing Directive (EU) 2024/825 on consumer engagement in the green transition (the ‘Green Transition’ Directive) expired on March 27, 2026.
In Hungary, transposition was achieved through an amendment to Act XLVII of 2008 on the Prohibition of Unfair Commercial Practices against Consumers, adopted in December 2025. This is to be replaced by the new rules that will take effect on September 27, 2026. “The time remaining until then is relatively short for preparation, especially given the wide range of potential stakeholders,” Fruzsina Kónya, an expert at the international law firm Taylor Wessing points out.
As she explains, the directive does not radically overhaul existing consumer protection rules, but it creates a much clearer and more detailed regulatory framework for assessing environmental claims. One of the most important changes is that the concept of an environmental claim is now explicitly defined and extends to visual elements as well as brand and product names. All such claims must be supported by objective, verifiable, and up-to-date evidence. General, vague statements – such as “green” or “climate-neutral” – may be subject to increased scrutiny by authorities if they are not accompanied by a clear and specific explanation. Stricter rules also apply to emissions offset claims based on carbon credits.

Conscious preparation needed
The time remaining until September 27, 2026, should be used for conscious preparation: by conducting a comprehensive review of all environmental claims; documenting and verifying the evidence behind these claims; assessing the legal compliance of sustainability labels and brand elements conveying environmental messages (such as trademarks); and establishing internal collaboration processes between legal, compliance, and marketing departments.
“Non-compliant practices can lead to significant consumer protection fines. Ensuring the legal compliance of environmental communications will become a strategic priority in the coming months – and in many cases, it is advisable to involve experts early in the preparation phase,” Fruzsina Kónya concludes in the article.