ECGT on Amazon: What Sellers and Vendors Need to Know About Environmental Claims and Guarantees
Since 27 September 2026, the EU directive on empowering consumers for the green transition, ECGT for short (Directive (EU) 2024/825), has been in force. It is EU consumer law and applies to anyone selling to consumers in the EU, online and in stores. Amazon is only one of the channels it covers, and sellers and vendors often mix up two parts that are legally separate. This article sets out both parts and shows what to do on Amazon in practice. It is not legal advice. For individual cases, a legal review is worth having.
What the directive regulates in principle, regardless of channel
The ECGT has two parts with different legal bases, different effort, and different risk.
| Part 1: Environmental claims | Part 2: Statutory warranty and guarantee | |
|---|---|---|
| Core question | What may be said about the environment, durability, and repairability? | Which information on consumer rights must be displayed? |
| Legal basis (DE) | UWG (German Act Against Unfair Competition), unfair competition | BGB (German Civil Code), consumer rights, specified by Regulation (EU) 2025/1960 for the form and design of the labels |
| Applies to | Title, bullets, description, A+, images, packaging, inserts | Product detail page online, point of sale in store |
| Effort on Amazon | Medium: review and clean up listings | Low: usually nothing, otherwise three attributes |
| Risk | Deactivation by Amazon, warning letters | Warning letters |
Part 1 regulates what may be said about environmental characteristics. Its basis is competition law. Part 2 regulates which consumer rights must be displayed. Its basis is the German Civil Code. Both duties apply whether the sale runs through Amazon, your own online shop, or a physical store.
Who and which products this applies to
The duty applies to anyone who advertises environmental characteristics, durability, or repairability, or who must provide consumer-rights information. One example: a manufacturer of food processors who advertises "made from recycled plastic" in the title and at the same time grants a two-year manufacturer's guarantee falls under Part 1 and Part 2 of the directive with the same product page. That includes the title, bullet points, description, A+ content, images, packaging, labels, and inserts. On Amazon, every place where text or an image appears counts, including the brand store and Sponsored Brands headlines.
Resellers also check whether their products meet the requirements. If documents are missing, they are requested from the supplier as quickly as possible.
Part 1: Environmental claims
The directive separates two groups of claims: some are never allowed, others only with valid proof. A vague promise such as "sustainable" is not enough for that. A documented fact, such as a recognized certification or a test series, is.
Claims that are always prohibited
- General environmental claims such as "sustainable", "environmentally friendly", "green", or "climate friendly", unless a recognized environmental label supports them.
- "Climate neutral" or "net zero", if the claim is based solely on CO₂ offsetting. Offsetting does not reduce the product's actual emissions.
- Selling a legal requirement as an environmental benefit, for example "free from X" when X is banned across the EU anyway.
- Presenting one aspect as the whole, for example "sustainable product" when only the packaging is recycled.
- Future promises such as "climate neutral by 2030", unless all five conditions are met at the same time: a publicly verifiable commitment, a detailed implementation plan with measurable and time-bound targets, resources that have been allocated, regular independent verification, and publicly available verification results.
- Comparative claims without stating the methodology, the products and suppliers compared, and without measures to keep the comparison data up to date.
- Benefit claims that are not relevant to the purchase decision.
- Self-created seals or logos without certification by a recognized third party.
Claims that are allowed only with proof
| Type of claim | Allowed if | Example allowed | Example prohibited |
|---|---|---|---|
| Durability, repairability | Test data or a recognized method is available, spare parts are available | "Tested for 10,000 cycles" | "durable" without proof |
| Energy efficiency | Official standard or measured values | "Energy efficiency class A" | "energy saving" without a reference |
| Recyclability | Material and recycling infrastructure are documented, conditions are stated | "Cardboard, dispose of with waste paper" | "fully recyclable" without conditions |
| Biodegradable, bio-based | Conditions are stated, test data is available | "industrially compostable according to EN 13432" | "compostable" without conditions |
| PFAS-free | Laboratory results are available | "PFAS-free, laboratory tested" | "PFAS-free" without proof |
| CO₂ footprint | Independently verified life-cycle data, method explained in an understandable way | "x kg CO₂e per unit, verified by …" | "low carbon" |
Additional limits apply to durability and repairability. Durability must not be misrepresented, and known limitations must not be concealed. Repairability must not be claimed if no spare parts are available. Early replacement of consumables must not be encouraged. And functional limitations with non-original accessories must not be concealed.
Which proofs are recognized
Three types of proof count as evidence: the EU Ecolabel under Regulation (EC) No 66/2010, national or regional Type I ecolabels under EN ISO 14024 such as the Blue Angel, the Nordic Swan, the Austrian Ecolabel, or the Dutch Milieukeur, and demonstrated top environmental performance under other EU legislation, for example energy efficiency class A under energy labelling.
The proof must match the specific claim. The EU Ecolabel covers a claim such as "biodegradable" only if the ecolabel criteria for that product explicitly require it.
Implementation on Amazon
What needs to be done depends on whether an offer is newly created, already exists, or comes from a reseller.
New offers
New offers contain no prohibited claims. For claims that require proof, the document is uploaded in Manage All Inventory, with three attributes: compliance media content type, using only document types 8 to 22, compliance media language, and compliance media source as a direct PDF download link, not a link that only opens the PDF in the browser.
Existing offers
If prohibited claims are already in the listing, they are removed through the function for changes to the product detail page. If a listing contains a claim that requires proof and has none, the document is submitted by editing the offer and product information, or the claim is removed.
Resellers
Anyone reselling other brands checks the products' conformity and requests missing proof from the supplier as quickly as possible.
Amazon can deactivate an offer even if proof was submitted that Amazon considers invalid.
Part 2: Legal guarantee notice and GARAN label
Part 2 brings two different labels. The legal guarantee notice reminds customers of the statutory warranty and applies automatically to every consumer product in the EU. The GARAN label additionally makes a voluntary commercial durability guarantee from the manufacturer visible, and it appears only when certain conditions are met. The following table shows the difference at a glance. Both labels are then covered in detail.
| Legal guarantee notice (harmonised notice) | GARAN label (durability guarantee) | |
|---|---|---|
| Content | Reminds customers of the statutory warranty of at least two years and of the rights to repair, replacement, or a refund | Shows a voluntary durability guarantee from the manufacturer |
| For which products | All products for consumers in the EU | Only if all four conditions are met |
| What Amazon does | Displays it automatically on all EU pages | Generates the label automatically from three attributes |
| What to do | Nothing | Only for a matching guarantee: maintain three attributes |
What the two labels look like
Both labels are fixed by the European Commission. The design cannot be customized. The legal guarantee notice contains a scannable QR code with further information. It states that the statutory warranty runs for different lengths of time depending on the EU country, but at least two years, when it can be claimed, and how the seller helps further. Printed, it must be at least A4 size. In a store it may be in color or black and white. Online it must be in color.
The GARAN label carries the title "GARAN", a checkmark as confirmation of the durability guarantee, a calendar symbol for the term in years, a visual reference to the statutory warranty right, and a QR code with further information. Only three details can be changed: the term of the guarantee, the brand, and the model number. Printed, it must be at least 95 by 100 millimeters. Online it must be in color and may be shown in a nested form that expands on click or on mouse hover.
The four conditions for the GARAN label
- The guarantee comes from the manufacturer or importer, not from the retailer. The brand owner of a private label also counts as the manufacturer.
- It is free of charge for the customer.
- It covers the entire product, not only individual parts.
- It runs for longer than two years.
Does the GARAN label also apply to a guarantee of exactly two years?
No. According to the official classification by the European Commission on Your Europe, the commercial durability guarantee must run for longer than two years for the GARAN label to be used. A manufacturer's guarantee of exactly two years does not produce a GARAN label. The legal guarantee notice still applies, and it applies to every product, whether or not there is an additional manufacturer's guarantee. The assumption that every product with a two-year manufacturer's guarantee automatically gets a GARAN label does not match this source.
How Amazon implements the two labels
According to consistent reporting in trade media, as of September 2026, Amazon is expected to display both elements automatically: the legal guarantee notice on all EU product pages, regardless of a guarantee, without sellers having to do anything. The GARAN label should appear only when brand, model number, and guarantee duration are fully maintained through the catalog attributes. It is then generated automatically in the EU format and placed under "Safety and product resources" on the product detail page. A separate image upload is not required for this.
Observation from practice: Amazon itself had not issued an official statement to the Händlerbund by 17 September 2026. The classification above comes from industry sources and from Amazon's seller help. Whether the implementation works completely on the effective date can only be checked on your own current product page.
The three attributes that must be maintained
| Attribute | Content | Example |
|---|---|---|
| Brand | Brand name | Sample Brand |
| model_number | Model number or identifier | MB-4815 |
| extended_warranty_duration | Total duration including the statutory two years, must be longer than two years | "5 years" |
The attributes are maintained in Manage All Inventory, through the file template for many ASINs or through the API. Without a fully maintained model number attribute, no label is displayed.
Does the label have to go on the packaging?
Online, the duty sits with the retailer at the point of sale. The customer must see the information before buying. On Amazon, the product detail page does this automatically. There is no duty to also print the label on the packaging for online sales. According to the European Commission, the manufacturer may voluntarily place the GARAN label directly on the goods or the packaging. That mainly helps physical retail. A guarantee seal on the packaging then counts as advertising a guarantee and must match the maintained attributes.
What if the label is not visible today?
If a platform does not display a label on the effective date for technical reasons, even though your own data is fully maintained, that hardly protects the retailer legally. According to the Händlerbund's assessment, warning letters in practice are directed at the sellers, not at the platform. It is therefore advisable to keep checking your own product pages and to document a missing label with a screenshot and a support ticket, regardless of who caused the delay.
Tricky cases
- A guarantee extension on registration, for example "plus one year with online registration": whether this meets the GARAN conditions is not clear. A legal review makes sense before the attributes are maintained.
- Guarantees with exclusions for wear parts, the battery, or accessories: strictly speaking, this is not a guarantee on the entire product, so rather no GARAN label.
- Advertising a guarantee in the text, for example "5-year guarantee" in bullets or images, while the attributes are not maintained: risk of a warning letter. Text and attributes must match.
- Vendor Central: Amazon's help is written for Seller Central. How the attributes are maintained for vendor ASINs is clarified by Vendor Support.
Was this not always the case?
Partly. Guarantee statements already had to be clear and complete. That is governed by Section 479 of the German Civil Code (BGB). Anyone advertising a guarantee had to make the conditions accessible. What is new is the uniform EU label format, which must be visible before purchase, and the legal guarantee notice for all products, even without any guarantee at all.
Special case: products with digital elements
For smart devices, connected household appliances, electronics with integrated software, or digital products such as apps and software, additional disclosure duties apply. Negative effects of a software update on how the product works, or on the use of digital content, must not be concealed. And an update must not be presented as necessary if it only contains feature improvements.
Who is liable if a notice is wrong or not displayed at all
The retailer bears the risk, not Amazon. That also applies if Amazon does not display a notice, or displays it incorrectly, for technical reasons. In practice, warning letters are directed at the seller.
Observation from practice: a spot check on 25 September 2026 still showed the previous warranty wording on one reviewed product page, not the notice in the new EU format. That is a single observation before the effective date, not a statement about the current state. Checking your own offers remains necessary.
If an affected product is better taken out of sale
If a product is not to be adapted, it is removed through Manage All Inventory. For Fulfillment by Amazon, the inventory must also be removed from the fulfillment centers, otherwise notifications remain in place.
Checklist: check step by step whether an offer is affected
Environmental claims
- All listings scanned for prohibited terms: text, A+, images, store, ads
- Prohibited claims removed or rewritten in concrete terms
- Proof for allowed claims collected and uploaded as a direct PDF link
- Packaging and inserts requested from the manufacturer or checked
- Content guidelines, templates, and text modules updated
Statutory warranty and guarantee
- Clarified with the manufacturer: is there a free guarantee on the whole product for more than two years, and under which conditions
- If yes: brand, model number, and total duration maintained for each ASIN
- Guarantee advertising in texts and images checked against the attributes
- Spot check done: legal guarantee notice visible in the EU format, GARAN label visible where it was maintained
- If not visible: screenshots taken and a ticket opened with Seller or Vendor Support
How REVOIC can help
REVOIC is an agency, not a seller or vendor, and does not take legal responsibility for customers' offers. Within the agreed scope, REVOIC can search listings for the terms mentioned, gather proof, and maintain the attributes for compliance media and guarantees in Seller Central or Vendor Central. Whether and how strongly individual products are affected is settled in the end by a legal review.
