Recently, a regulatory affairs manager sent us this unusual request:

“I’m getting in touch because I’d like to know whether there is a quick way to download all of our approved artworks from My Media Connect. We need them because, under the new Empowering Consumers legislation, we have to review every one of them for green claims, and downloading them one by one from the platform would be extremely tedious. Could you help us with this?”

As this customer has thousands of approved artworks in MyMediaConnect, the request struck us as unusual, but downloading them all by hand would certainly have been tedious.

It turned out that their goal was to check whether their products complied with the ECGT (Empowering Consumers for the Green Transition) Directive, commonly known as the Empowering Consumers Directive or the “anti-greenwashing” directive. In other words, a much-needed review, and one that shows they take their role seriously.

And what about you: do you know what this legislation involves? We explain it here, focusing on what really matters for regulatory affairs, packaging, marketing and senior management teams.

What is the Empowering Consumers Directive (ECGT)?

Directive (EU) 2024/825, known as “Empowering Consumers for the Green Transition” (ECGT), is the European legislation that tightens the rules on environmental and social claims aimed at end consumers.

It was adopted on 28 February 2024, published in the OJEU on 6 March 2024 and must be transposed into national law by 27 March 2026, with full application from 27 September 2026.

In Spain, the directive is being transposed through the draft Sustainable Consumption Bill (Anteproyecto de Ley de Consumo Sostenible), which amends the General Law for the Protection of Consumers and Users and introduces new prohibitions and requirements for green claims in advertising, packaging, landing pages and any B2C commercial communication.

The key point: there is no grace period for packaging that has already been produced. The new rules apply from 27 September 2026 to products placed on the market from that date, regardless of when the packaging was designed or printed.

Who does it actually affect?

Any company that communicates sustainability to end consumers in the EU, whatever its size.

This includes:

Food, beverage, personal care, household and other brands
Distributors and retailers with own-label products
Companies that use claims on packaging, in advertising, e-commerce, social media, leaflets, etc.

The directive does not regulate internal B2B communications or corporate sustainability reporting (CSRD), but it does cover all commercial communication aimed at end consumers that suggests an environmental or social benefit.

If your packaging says “eco”, “sustainable”, “planet-friendly”, “reduced footprint”, “biodegradable”, “climate neutral”, etc., you fall within the scope of this legislation.

Which claims are banned or heavily restricted?

The ECGT sets out a closed list of practices deemed misleading unless very strict conditions are met. The most relevant for packaging and artworks are:

1. Generic environmental claims without evidence

Terms such as:

“Ecological”, “eco”, “green”, “sustainable”
“Environmentally friendly / planet-friendly”
“Biodegradable”, “compostable” (without specifying conditions and standards)
“Reduced footprint”, “lower environmental impact”
“Climate neutral”, “carbon neutral”, “CO₂ offset”

These are banned as generic claims unless you can demonstrate recognised excellent environmental performance, with verifiable data, a public methodology and, in many cases, third-party verification.

In practice: it is no longer enough to put “more sustainable packaging” on the front of pack without explaining in what way, by how much, how it is measured and who verifies it.

2. Claims based solely on emissions offsetting

Claiming that a product or brand is “carbon neutral” because you have bought carbon credits outside your value chain is prohibited.

What counts is real emissions reduction, not offsetting. Climate neutrality claims will only be admissible if they are based on actual reductions within the value chain and follow recognised methodologies.

3. Unverifiable sustainability labels and seals

Any in-house or third-party label suggesting sustainability must be based on a transparent, open and audited certification scheme, or be established by a public authority.

“Home-made labels” with no public criteria, no external audit and no clear governance are a direct greenwashing risk.

4. Misleading information on durability, repairability and recyclability

The law broadens the concept of unfair commercial practice to include false or confusing information about:

Product durability
Repairability (parts, availability period, difficulty)
The actual (not theoretical) recyclability of the packaging

If your packaging says “100% recyclable” but in practice that material is not collected or recycled in most municipalities, you may be in breach.

What does the legislation require in terms of evidence?

From 27 September 2026, every relevant environmental claim on packaging and in commercial communications must meet at least three conditions:

Verifiable data
Internal estimates or statements of intent are not enough. You need records, calculations and evidence that can be reviewed.
A public, understandable methodology
You must be able to explain how you measure each claim: the standard used, scope, unit of measurement, reference period, etc.
Third-party verification (for sensitive claims)
For claims about environmental impact, emissions reductions, social benefits, etc., a documented external audit is expected.

This turns regulatory affairs, packaging and compliance teams into critical gatekeepers for every communication that goes to print or into a campaign.

Why this has a direct impact on your artworks

Until now, many companies treated green claims as a “marketing detail” or a line of copy added to the design whenever there was space. Under the ECGT, every claim is a regulated asset, carrying legal and reputational risk.

This means:

Reviewing the entire packaging portfolio for potentially problematic claims.
Cross-checking each claim against the available evidence (studies, LCA, certifications, standards).
Updating artworks to remove, reword or qualify claims that are no longer admissible.
Ensuring that the approved version in the system is the compliant version and that any change goes through regulatory control.

It is no coincidence that our customer’s regulatory affairs manager wanted to download all approved artworks in one go: they need to carry out a large-scale screening before 27 September 2026.

The operational challenge: thousands of artworks, hundreds of SKUs, multiple markets

Imagine a company with:

Several thousand active artworks
Dozens of product categories
Multiple countries, languages and local regulations
Marketing, packaging, regulatory, legal and production teams all involved

Carrying out a “green claims sweep” by downloading artworks one by one is simply not feasible in terms of time and resources. It also increases the risk of:

Reviewing obsolete versions
Losing traceability of which claim was approved and when
Missing differences between markets (a claim that is valid in one may not be in another)

This is where artwork management stops being purely a “workflow” matter and becomes a regulatory compliance issue.

How MyMediaConnect helps you tackle the ECGT in packaging

MyMediaConnect is not just a design approval tool. It is a centralised platform that enables you to:

1. Keep a single, up-to-date inventory of all artworks

All packs, labels, secondary packaging, POS and promotional materials are in one place, with:

The current approved version
Version history
Comments and decisions from every stakeholder

This means you know exactly what is on the market and what is in the pipeline.

2. Filter and prioritise by claim, category, market and risk

Although every implementation may differ, the logic is clear: if you can tag or associate claims with artworks (for example, through metadata, key comments or attached documents), you can:

Quickly identify all packs that include terms such as “eco”, “sustainable”, “carbon neutral”, etc.
Prioritise reviews by risk (the most sensitive claims, the strictest markets, the most exposed categories).

3. Centralise collaboration between regulatory, marketing and packaging

The ECGT requires regulatory affairs to have a real say in claims that used to be decided by marketing alone. With a platform such as MyMediaConnect:

Regulatory teams can comment, request evidence and block approvals if documentation is missing.
Marketing and design see comments in context, on the artwork itself, rather than in endless email threads.
There is a record of who approved what, on what grounds and on what date.

This is crucial in the event of an inspection or complaint: you can demonstrate that there was a documented review process.

4. Reduce the risk of non-compliant versions reaching the market

One of the biggest risks is having the following coexist:

An “old” version with non-compliant claims
A “new” version already adapted to the ECGT

If the approval workflow is not centralised, it is easy for production or the supplier to print the wrong version. MyMediaConnect helps to ensure that:

Only the latest approved version is accessible as “current”
Any significant change goes back through the validation workflow
There is full traceability across the artwork lifecycle

A real case: from “unusual request” to strategic project

Going back to the original request from our regulatory affairs customer: what at first seemed an “unusual” request (downloading thousands of artworks to review green claims) is in fact a symptom of something much bigger.

This company is:

Taking the ECGT seriously
Recognising that non-compliance is not only a legal risk, but also a risk to reputation and consumer trust
Understanding that reviewing claims is a cross-functional project affecting packaging, marketing, legal, supply chain and senior management

The fact that they already have thousands of approved artworks in MyMediaConnect is a huge advantage: some of the heavy lifting (centralisation, history, collaboration) has already been done. What they need to do now is:

Define a claims screening method
Assign owners by category and market
Use the platform to prioritise, comment on and approve the necessary updates

In other words: turn a regulatory requirement into an opportunity to organise and professionalise packaging management.

What you can do now (before 27 September 2026)

If your company has packaging with environmental or social claims, these are the minimum recommended steps:

Inventory all artworks with claims
Identify where terms such as “eco”, “sustainable”, “biodegradable”, “carbon neutral”, etc. appear on packaging, in advertising and in e-commerce.
Classify by risk level
Prioritise the most sensitive claims (climate neutrality, biodegradability, “lower impact” comparisons, etc.) and the most exposed markets.
Gather the available evidence
For each claim, collect the studies, LCAs, certifications, standards and methodologies that support it. If none exist, flag that claim as “to be reworded or removed”.
Update the artworks and approve them formally
Use your artwork management system to:
- Propose new versions without problematic claims or with more precise wording
- Involve regulatory affairs in the final approval
- Keep a traceable record of the decision
Communicate the new rules internally
Make sure marketing, design and external agencies are aware of the new restrictions and the claims validation process.
Put an ongoing monitoring plan in place
This legislation is not a one-off. Every new launch, reformulation or campaign must go through the same filter.

Why this is more than compliance: it is about brand trust

The ECGT is not here to be a “nuisance”, but to restore the trust of consumers who are saturated with vague, contradictory or downright false claims.

Brands that:

Cut out the green noise
Keep only robust, verifiable claims
Are transparent about what they actually do

will gain credibility in the medium term. Those that try to “slip through” dubious claims are exposing themselves to:

Penalties from consumer and competition authorities
Complaints from consumers and NGOs
Reputational damage that is hard to repair

In this context, good artwork management is not a cost; it is an insurance policy.

The role of MyMediaConnect in your ECGT roadmap

MyMediaConnect does not replace your legal or regulatory affairs teams, but it does give them:

Full visibility of the packaging portfolio
A shared space to discuss and validate claims
Traceability of decisions and versions
The ability to scale reviews to hundreds or thousands of SKUs without grinding to a halt

Our customer’s “unusual request” is, at heart, a sign that the market is maturing: packaging is no longer just a graphic medium; it is a regulatory document.

If your company wants to reach 27 September 2026 with peace of mind, now is the time to treat artworks for what they are: critical assets for compliance and brand trust.

From “unusual request” to competitive advantage: how the Empowering Consumers Directive (ECGT) is changing the management of artworks and green claims on packaging