The EU Directive on Empowering Consumers for the Green Transition (also known as the “ECGT" or “EmpCo” Directive) aims to promote sustainable consumption by:
- tackling unfair commercial business practices, such as greenwashing, that prevent consumers from making sustainable consumption choices; and
- improving consumer information to enable sustainable transactional decisions.
Companies should use the period for transposition into national laws to familiarise themselves with the new requirements and, if necessary and commercially viable, adapt their practices. For more information on the Directive, see our detailed client briefing.
EU Member States had to implement the Directive into national legislation by 27 March 2026. On 28 May 2026, the European Commission decided to open infringement procedures by sending letters of formal notice to 20 Member States (including Belgium, Spain, France, Luxembourg, Netherlands and Portugal) for failing to communicate the complete transposition of the Directive. The Member States concerned now have two months to respond and notify their complete transposition measures to the Commission. In the absence of a satisfactory response, the Commission may decide to issue a reasoned opinion.
The Directive starts applying from 27 September 2026.
We are tracking the implementation of this Directive in selected EU Member States of key relevance.
Belgium
| Status | The Council of Ministers has approved a preliminary draft bill transposing the Directive, which would amend Book I and Book VI of the Code of Economic Law. The preliminary draft bill has been submitted to the Council of State. |
| Next steps and timing | N/A |
| Legislative documents | N/A |
| Description | N/A |
Contacts: Florence Danis, Guillaume Croisant
France
| Status | The draft bill was examined by the competent Senate parliamentary commissions and debated and adopted by the Senate on 18 February 2026. The draft bill was referred to the National Assembly on 20 February 2026. |
| Next steps and timing | In line with the French legislative process, the bill has been referred to the National Assembly, where it will be examined by the competent parliamentary commissions, then debated and voted by the National Assembly. Once the draft has been adopted in identical terms by the Senate and National Assembly, it will be promulgated. |
| Legislative documents | Articles 20 and 21 of the Draft bill No. 118, containing various provisions for the adaptation of French law to EU law with regard to economic, financial, environmental, energy, information, transport, health, agriculture and fishing matters. Explanatory memorandum on Draft bill No. 118 Draft bill as adopted by the Senate (18 February 2026) |
| Description | Articles 20 and 21 of the draft bill amend the French Consumer Code and the French Environmental Code to implement the Directive. Article 20 modifies the French Consumer Code to notably (i) introduce a definition of ‘environmental claims’, (ii) strengthen pre contractual information provided to consumers, and (iii) extend the concept of misleading commercial practices in relation to environmental claims. Article 21 amends the French Environmental Code provisions relating to prohibited environmental claims concerning products and their packaging. |
Contacts: Jean-Charles Jais, Claudia Cavicchioli
Germany
| Status | Following its adoption, the implementation act has been published in the Federal Law Gazette on 19 February 2026. |
| Next steps and timing | As stipulated by the Directive, the new rules will enter into force on 27 September 2026. |
| Legislative documents | Federal Law Gazette (19 February 2026) |
| Description | Germany implements the Directive by way of a one-to-one transposition. Read more in our blog post on the initial draft. |
Contacts: Julia Grothaus, Mirjam Erb
Italy
| Status | On 6 February 2026, the Council of Ministers definitely approved the draft legislative decree transposing the Directive. On 9 March 2026, the legislative decree was published in the Official Gazette no. 56. |
| Next steps and timing | The legislative decree will enter into force on 24 March 2026. The provisions will apply from 27 September 2026. |
| Legislative documents | Legislative Decree (20 February 2026) |
| Description | The legislative decree introduces amendments to the Consumer Code (Legislative Decree No. 206 of 6 September 2005). The measure strengthens the protection against misleading ‘green claims’, expanding the list of prohibited commercial practices, and introduces new ways of providing clear and verifiable information for the benefit of consumers. The provisions will apply from 27 September 2026. |
Contacts: Alessandro Villani, Alessandro Salvador
Luxembourg
| Status | On 29 October 2025, Luxembourg introduced draft bill No. 8648 regarding the Directive. On 21 May 2026, the Parliament voted in favour of the draft bill in a first constitutional vote. |
| Next steps and timing | A request for exemption from the second vote has been filed. |
| Legislative documents | Submission of the bill (29 October 2025) Draft bill No 8648 (21 May 2026) Note: All legislative documents are available here in French. |
| Description | The aim of the bill is to amend the Consumer Code to improve consumer information about the expected lifespan of goods. This involves improving details about the manufacturer’s commercial durability guarantee through a standardised label. The bill also seeks to make information on the repairability of goods more accessible, by providing a repairability index from the manufacturer or by sharing information about spare parts and repair instructions. Another objective is to counter unfair commercial practices that mislead consumers and prevent them from making sustainable consumption choices. |
Contacts: Guy Loesch, Louis-Eudes Giroux
The Netherlands
| Status | The draft bill implementing the Directive was approved by the Council of Ministers on 11 July 2025. The proposal was subsequently submitted to the Advisory Division of the Council of State. On 24 September 2025, the Council of State issued its opinion without further comment, recommending that the proposal proceed to the House of Representatives. On 22 December 2025, the legislator submitted a draft bill to implement the Directive, together with its explanatory memorandum, to the Dutch House of Representatives. On 13 January 2026, the draft bill was discussed in the Committee for Economic Affairs of the Dutch House of Representatives during which the procedural steps and order of business were established. On 23 April 2026, the draft bill was adopted by the House of Representatives without a formal vote due to the apparent absence of objections. |
| Next steps and timing | The draft bill has been submitted to the Dutch Senate for consideration, where the written preparatory phase is currently underway. This will be followed by plenary debate and a vote. If accepted, the draft bill will enter into force by a date to be published by Royal Decree. It is noted in the draft bill that the Directive should be transposed into national legislation as per 27 March 2026 and that the rules will apply as of 27 September 2026. The transposition deadline has not been met, and it remains uncertain when transposition will be completed. |
| Legislative documents | Draft bill (22 December 2025) Explanatory memorandum (22 December 2025) |
| Description | The draft bill will amend the Book 6 of the Dutch Civil Code to implement the Directive. |
Contacts: Daniella Strik, Bas van Niekerk
Portugal
| Status | N/A |
| Next steps and timing | N/A |
| Legislative documents | N/A |
| Description | N/A |
Contacts: Ricardo Guimarães, José Gonçalves Pereira
Spain
| Status | In July 2025, the government approved a first draft and opened a consultation period. |
| Next steps and timing | The consultation period ended on 31 August 2025. The government must now approve a new draft. This new draft will be sent to the Parliament for discussion and enactment. |
| Legislative documents | Preliminary Draft Law on Sustainable Consumption (1 July 2025) |
| Description | In addition to this Directive, the law also transposes the Right to Repair Directive. The law is structured on several key principles that reshape consumer protection, including addressing unfair business conduct, fostering more informed purchasing choices, supporting the repair of products, and guaranteeing that environmental information about goods and services is transparent, dependable and verifiable. |
Contacts: Alex Ferreres, Mercedes Agreda
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