On 30 June 2026, the Consumer Protection Cooperation (CPC) Network published enforcement guidance setting out how national consumer authorities should approach “old stock” under the EU Empowering Consumers for the Green Transition Directive (ECGT). ECGT introduces rules for environmental and social sustainability claims, early obsolescence and the use of sustainability labels.
The guidance addresses products manufactured, ordered or placed on the market before the new rules on environmental claims and sustainability labels begin to apply on 27 September 2026.
While businesses are expected to work towards full compliance by that date, the guidance confirms that enforcement should be proportionate and take account of the practical challenges associated with existing stock.
Key expectations:
Companies are expected to make “all reasonable and proportionate efforts to achieve full compliance with the ECGT rules by 27 September 2026.”
For companies, this includes:
- removing or correcting online claims;
- updating advertising and promotional materials;
- adapting future packaging and new orders;
- using stickers, removing labelling, or implementing similar corrective solutions;
- displaying corrective information at the point of sale;
- coordinating with suppliers and other actors in the chain; and
- keeping records showing the steps taken and compliance information.
Enforcement is to be phased and risk-based, with priority on claims already subject to enforcement, online claims, practices most harmful to consumers, non-packaging claims, and products with a shorter shelf life, with assessments to be made on a case-by-case basis.
Enforcement is to avoid disproportionate costs to businesses or unnecessary environmental harm (e.g. product recalls or product destruction).
Authorities are to take a “compliance-oriented before sanction-oriented approach” in justified old stock situations, meaning the priority is to be on guidance and corrective actions before sanctions.