5 Dec 2025

Navigating the ECGT Directive: What B Corps and Consumer Brands Need to Know

By Ro Egglesfield
As the September 2026 deadline approaches for the EU’s Empowering Consumers for the Green Transition (ECGT) directive, we sat down with Amy Bourbeau and Ro Egglesfield from Seismic to understand what this means for businesses operating in the EU market.

Understanding the Basics

What exactly is the ECGT directive and who does it affect?

Amy: The ECGT directive is similar to ASA guidelines (the UK’s Advertising Standards Authority rules) – the main focus is protecting consumers and driving forward EU’s green deal commitments to make the EU the first climate-neutral continent by 2050, focusing on boosting resource efficiency, promoting a clean and circular economy, restoring biodiversity, and cutting pollution. It applies to any company selling products or services to consumers in the EU – whether you’re directly operating there or just have a website that somebody in the EU can access and buy from. Even if you’re operating from the UK, if an EU consumer can purchase from you, it applies.

So this isn't just about B Corps then?

Ro: Absolutely not. Whilst we’re seeing two main areas of action – one with B Corps already operating in the EU who need to update their packaging and move forward with recertification, and another with high-growth businesses planning EU expansion – this affects any consumer-facing brand making sustainability claims in the EU.

Amy: Yes and if you have a certification related to sustainability like B Corp, there are very specific requirements you need to meet.

The B Corp Connection

How does this specifically impact B Corps?

Amy: For B Corps who fall under the directive, you can only use the B Corp logo and communicate that you’re a B Corp if you meet the requirements under the ECGT.
There are two elements: first, it has to be a transparent standard – so consumers can understand what the certification actually means. Second, the certification needs to be audited and confirmed by a third-party auditor. This is actually part of what has pushed the evolution of the B Corp standards to take the shape they have.

Ro: The new B Corp standards are much more about evidencing rather than just intent. You have to put policies in place and track the impacts of those policies and decisions. It’s really embedded within the business – it’s great to see this increased rigour on how social and environmental improvements are made and how B Corps are raising the roof on demonstrating performance.

Timeline and Urgency

What’s the timeline businesses are working with?

Amy: The directive comes into effect in September 2026, so companies need to be adhering to it from then. There’s another important date too – March 2026 is when EU member states have to have transposed the directive into their local laws. Member states could add their own practical additions to it, and will be applying their own monitoring, enforcement, and penalties.

Ro: The verification process from pressing submit to having completed the audit should take between two to six months. So if you’re counting back from September 2026, you’re looking at needing to submit in the first three months of 2026 essentially.

That’s quite tight, isn’t it?

Ro: Everyone’s getting prepared to submit as soon as possible from January onwards. The challenge is there’s quite a lot of work that businesses need to do to both meet the requirements and demonstrate the evidence of those requirements before their year zero, which is the year they’ll be certified on. Year zero is your certification year – the baseline that your continuous improvement will be measured from. You’ll need specific policies and evidence in place before this point, with targets getting progressively more ambitious by years three and five.

Immediate Actions for B Corps

What’s the very first thing B Corps need to do right now?

Ro: Well, first of all, B Corps need to inform B Lab if they believe they are impacted by the directive. B Lab is recommending that companies complete this self-declaration through their B Impact Assessment portal. You are responsible for determining whether the directive applies to your business.

Is there a deadline for this?

Ro: Yes – B Lab recommends completing this self-declaration by the 30th November 2025. So it’s an immediate call to action. They need to self-declare so B Lab can understand the scale of businesses affected and provide appropriate support.

Where can B Corps access this information?

Ro: B Lab has published some really comprehensive guidance on their knowledge base, which includes details about the self-declaration process and what it means for your certification. You should access your B Impact Assessment to flag that you’ll be impacted by the change.

What B Corps Need to Do

Beyond self-declaring, what are the specific steps for B Corps?

Amy: The ideal scenario is they recertify before the directive comes in so they’re compliant. B Lab is also saying that companies should change the logo they use to one that includes the B Corp URL underneath it. That’s to increase transparency and meet the new requirements of the ECGT.

And if you don’t feel you are able to recertify in time, in order to be able to keep using the B Corp logo, companies that are impacted by ECGT need to update to the new logo and sign an updated agreement committing to certify on V2.1 by their next recertification date. The other pathway if you’re not going to recertify by that time, is to take the logo off packaging to reduce risk.

Ro: It’s not just on packaging though – it’s anywhere you market to EU Consumers e.g. websites, digital assets and print media.

Tell me more about this agreement option?

Ro: B Lab has introduced an updated agreement option. If you’re ECGT impacted but still have very significant gaps to meet the new standards, you may choose to sign this updated agreement, which means you commit to future certification. This allows you to continue using the B Corp logo.

It means you remain on version 1.6 of the standards, adopt the new logo use and claims guidelines by September 2026, and commit to completing recertification by your next recertification date – which might be September 2027. You do have to sign a waiver agreeing not to take legal action in case you’re impacted by the ECGT.

Alternative Pathway: The Updated Agreement Option

For B Corps with significant gaps who cannot meet the September 2026 deadline through recertification, there’s an alternative route:

  • Sign the updated B Corp agreement committing to future certification
  • Remain on version 1.6 standards temporarily
  • Adopt new logo and claims guidelines by September 2026
  • Complete recertification by your next scheduled date (potentially September 2027)
  • Sign a waiver agreeing not to pursue legal action if impacted by ECGT

This buys you up to an additional year but comes with the requirement that you’re actively working toward compliance, and accept any liability claims.

Beyond B Corp: Wider Implications

What about businesses that aren’t B Corps?

Amy: This is really important – anti-greenwashing affects everyone. I think a lot of companies do not think they’re greenwashing because it’s often not intentional. Best case scenario, they haven’t realised that the goalposts have changed. Often it’s laziness, or maybe someone put something on the website and it’s been long forgotten about.

Ro: Even things like saying ‘100% recycled bottle’ on the main label – you need to be very specific. Does that mean just the bottle, or does it include the packaging, closure, and label? Take Coca-Cola’s recent packaging, for example – it says “100% recycled bottle” on the main label. If you picked up that bottle, would you assume everything is 100% recycled, or just the bottle itself, excluding the packaging, closure, and label? Under ECGT, that distinction must be crystal clear.
You can’t just put ‘we’re green’ anymore. Anything you market to consumers needs to make sure it meets the ECGT requirements.

What about sustainability labels and certifications more broadly?

Ro: We’re already seeing enforcement action in this space! A TV advert by the Red Tractor standard was recently banned for exaggerating the scheme’s environmental benefits and misleading the public with claims like “from field to store all our standards are met.” So authorities are definitely scrutinising not just brands but the standards themselves.
Basically any certification or environmental claim you use must be verifiable, auditable, and stand up to scrutiny. The days of vague “green” messaging are over – if you can’t evidence it with specific, transparent standards and third-party verification, it needs to come off your packaging and marketing materials.
And ECGT is more than labels and certifications, it’s also about designing products for longevity including durability and recyclability.

First Steps for Businesses

What should businesses do first?

Amy: I think it’s a review of your communications, claims, and certifications – the three Cs. Any claims related to sustainability need reviewing to check where there might be risk. When it’s related to a certification or standard, you need to check in with that standard to see if and how it’s impacted.

Ro: The call to action is to understand how many gaps you’ve got. If they’re really significant and you can’t close them by September 2026, you need to prepare. This means engaging legal within your organisation, understanding the costs involved, and having a very strong discussion at leadership and board level on what you’re going to do. Because this isn’t just a sustainability team issue – it crosses legal, procurement, manufacturing, packaging, and communications. All the functions need to be involved. Often, the people driving this work don’t sit at executive or board level, and they need external support to help explain what needs to be done.

Given this is legislation, what’s the best-case scenario for getting this right?

Ro: Because we’re dealing with legislation here, the best-case scenario is working with a partner who can identify your gaps and put a rapid change plan in place, alongside lawyers to ensure legal compliance. Our clients are often sustainability managers, compliance officers, and operational leads who need external support to help articulate the cross-functional impact to senior leadership. This crosses legal, procurement, manufacturing, packaging, and communications – all the functions.

Amy: We offer an ECGT Comms Risk Review – not as a legal thing, but basically a scan of your public-facing communications, packaging, etc., to flag where there might be risks of non-compliance. But yes, given the legislative nature of this, you’ll need proper legal advice to ensure full compliance.

The Cost of Non-Compliance

What happens if businesses don’t comply?

Ro: There are three main cost buckets from a business perspective:

  1. Reputational costs – The cost of losing your ability to utilise B Corp in terms of reputation. You have to spend money communicating that change and managing the reputational risk of losing the certification.
  2. Commercial costs – The cost of commercial advantage by not having B Corp status. This would include loss of price premium, reduced access to retail shelf space (retailers like Waitrose prioritise B Corps), and losing competitive differentiation in your market.
  3. Legal costs – The cost of potential fines for non-compliance. We’ve read that fines could be up to 4% of revenue, although this will depend on how each member state transposes the directive into local law.

Amy: You can be penalised and fined if you’re not meeting the directive. From B Lab’s perspective, B Corps that don’t sign the updated agreement or complete recertification by September 2026 will lose the right to use the B Corp logo or refer to themselves as B Corps.

Ro: B Lab has said they may take legal action to protect the community and the brand. It’s not punitive, they have to protect themselves as well.

Who This Really Affects

Does company size matter?

Amy: Unlike some EU regulations that exempt SMEs, the directive applies to all businesses selling to consumers in the EU, regardless of size.

Your Action Plan: What to Do Now

Here’s your timeline for the next 12 months:

Immediate Actions (By November 30, 2025):

  • B Corps: Self-declare to B Lab through your B Impact Assessment portal
  • All businesses: Begin reviewing your communications, claims, and certifications (the “three Cs”)

By January 2026:

  • Complete a comprehensive gap analysis
  • Engage legal counsel and key stakeholders across all affected departments
  • Determine whether you can close gaps by September 2026 or need alternative arrangements
  • For B Corps: Decide whether to pursue recertification or sign the updated agreement

Q1 2026 (January-March):

  • Submit for B Corp recertification (allow 2-6 months for verification)
  • Begin updating packaging with new B Corp logo (including website URL)
  • Finalise compliance strategy with legal and sustainability teams

March 2026:

  • EU member states finalise transposition into local law
  • Review any additional country-specific requirements

By September 2026:

  • Full compliance with ECGT directive mandatory
  • All non-compliant claims, labels, and certifications removed
  • Updated website, marketing materials and packaging in circulation

Remember: The verification process takes 2-6 months, so submitting by March 2026 at the latest is essential to meet the September deadline.

Quick Reference Timeline

  • November 30, 2025: Self-declare to B Lab (B Corps)
  • Q1 2026: Submit for recertification
  • March 2026: EU member states transpose directive into local law
  • September 2026: ECGT compliance mandatory
For B Corps, the immediate action is to inform B Lab through your B Impact Assessment portal if you believe you’re impacted – B Lab recommends completing this by the end of October. For all businesses, now is the time to review your sustainability claims and certifications to ensure compliance ahead of the September 2026 deadline.