How ECGT Triggers Data Requests Up the Supply Chain

What the Empowering Consumers Directive actually does

The Empowering Consumers for the Green Transition Directive, often shortened to ECGT, is EU law that tightens the rules on how companies talk about sustainability to consumers. It bans generic claims such as "eco friendly" or "green" unless the specific detail is given clearly on the same medium or the product holds a recognised ecolabel such as the EU Ecolabel, sustainability labels that are not based on a certification scheme, and "carbon neutral" product claims that rest on offsetting. A claim can be words, but also an image, a logo or a product name. Images and colours on their own are not caught by the generic-claim ban, but they are judged case by case and must not mislead. From 27 September 2026 the rules apply, in the Member States that have transposed them, to anyone marketing to EU consumers, wherever the company is based. In the Netherlands they are part of the Civil Code and the ACM enforces them. Several other Member States are still writing them into national law.

It is a consumer protection law, so at first glance it looks like a problem for big consumer brands, not for an industrial or logistics supplier. The catch is in how those brands comply.

Why this lands on suppliers

A large company can only substantiate a claim about its product if it knows what is inside that product and how it was made. Part of that information lives with its suppliers. So the practical effect of the directive is a wave of data requests flowing down the supply chain: carbon footprints for specific materials, recycled content figures, energy and emissions data, and evidence behind any environmental attribute the customer wants to advertise.

For a supplier, this usually shows up as a request for a product carbon footprint, a supplier claims policy, or new clauses at contract renewal. The directive places no duty on suppliers in their B2B role. The legal risk stays with the customer, and the customer will favour suppliers that make its claims easy to prove. Claims in your own specification sheets and brochures matter too: once a customer copies one onto a consumer pack, it has to hold up.

What a supplier can do to be ready

1. Know what you are being asked. Most requests map to a small set of recurring topics: carbon data, materials and recycled content, and energy use. Read past questionnaires and find the pattern.
2. Find the data you already hold. Energy bills, production records, purchasing data and management systems already contain much of what is asked. The gap is usually in pulling it together, not in collecting something new.
3. Find the claims that depend on you. Check which customers sell to consumers and which of their claims rest on what you supply. That tells you which products and figures to prioritise, so effort goes where it counts.
4. Build it once, reuse it. A structured sustainability baseline turns each future request into a quick update rather than a fresh scramble. Each figure needs a documented method and source, so a customer or a verifier can check it. The article how to set up an ESG data management system walks you through what that looks like in practice.
5. Turn the answer into a selling point. A supplier that can hand over credible data quickly becomes the easy choice at tender, and a preferred supplier as customers tighten their own reporting.

The shift worth seeing

Treated as a single chore, a customer ESG request is pure cost. Treated as a prompt to organise your sustainability data properly, it becomes business intelligence: a clearer view of energy use, waste, cost and risk that helps the business beyond the questionnaire. That is the shift The Circular Bulb helps suppliers make.

This article reflects The Circular Bulb's interpretation of the current regulatory landscape and is provided for general information. TCB is not a law firm and does not provide legal advice. Verify the obligations that apply to your specific business before acting.