Published: 01 July 2026  (Updated: 01 July 2026)

Common Understanding on Old Stock under Empowering Consumers for the Green Transition Directive

The Directive on Empowering Consumers for the Green Transition (ECGTD) was adopted in February 2024 and introduces targeted amendments to the  Unfair Commercial Practises Directive and Consumer Rights Directive, in relation to environmental claims, sustainability labels and other related practises.  

Member States had until 27 March 2026 to transpose the Directive into national law, with the date of application to commence from 27 September 2026, meaning traders must ensure any environmental claims and sustainability labels in a business to consumer context comply with the provisions under the Directive.

On 30 June 2026, the Consumer Protection Cooperation (CPC) authorities agreed on a Common Understanding regarding the treatment of ‘old stock’ situations.  These are situations concerning products, packaging or sustainability labels that were manufactured, ordered, distributed or placed on retailers’ shelves before the date of application of the Directive.

The document agrees on common principles regarding these ‘old stock’ situations, to support a coherent approach to the treatment of existing products.  Whilst not a legally binding document, it does outline a set of non-exhaustive principles intended to provide a pragmatic approach for enforcement authorities.

The FAQ document published by the European Commission has also been amended to reference the Common Understanding.

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