European Commission publishes updated Questions and Answers document and Common understanding on old stock situations under the Directive on Empowering Consumers for the Green Transition

On Tuesday 30 June, the European Commission published the Common understanding on old stock situations under Directive (EU) 2024/825 on Empowering Consumers for the Green Transition. The European Commission also published its updated Questions and Answers for the ECGT Directive.

The Common understanding has been developed by the Consumer Protection Cooperation (CPC) Network to support a coherent approach to the treatment of such old stock situations. While this document does not constitute a formal position of the CPC network or a legally binding interpretation of the ECGT Directive, it sets out a non-exhaustive set of principles intended to provide a pragmatic approach to old stock situations.

Accordingly, national competent authorities are expected to consider this approach when exercising their enforcement powers, with a view to supporting a consistent application of the ECGT rules across the European Union. This common understanding remains without prejudice to other European Union and national law, to the powers and priorities of national competent authorities, and to the possibility for national competent authorities or courts from taking action in a specific case.

This common understanding concerns the enforcement treatment of old stock situations affected by the ECGT rules, in particular where environmental claims or sustainability labels appear:

• on packaging or on the product itself.

• online or in other digital interfaces.

• in advertising or other commercial communications linked to the product or trader.

Member States had until 27 March 2026 to transpose the Directive into national law. The Directive will apply on 27 September 2026.

The Common understanding on old stock situations can be found here: https://commission.europa.eu/document/264d8c70-2f9a-4955-8e7b-154d55a9b684_en

The Questions and Answers document can be found here: https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_en?filename=ECGT%20Directive%20FAQ_update%20with%20CPC%20Common%20Understanding.pdf

Contact: Lebo Mofolo, lmofolo@frucom.eu