2026.09.03

Position paper: Implementation of the ECGT Directive in Sweden

SWETIC Postage paper

Summary

SWETIC (Swedish Association for Testing, Inspection and Certification) welcomes
the implementation of Directive (EU) 2024/825 of the European Parliament and of the Council (Empowering
Consumers for the Green Transition (ECGT). The directive is an important step in strengthening
consumer trust in environmental and sustainability claims and counter misleading
marketing.

For the directive to have its intended effect, implementation needs to ensure that the actors involved
reviews and verifies sustainability labels, meets high standards of competence, impartiality
and independence. SWETIC believes that the established European accreditation system
and third-party assessment should form the starting point for how the requirements for competence,
Impartiality and independence are applied in the implementation of ECGT.

Accreditation and independence

The EU's quality infrastructure has long been based on accreditation under Regulation (EC) No
765/2008 and harmonised international standards for testing, inspection, verification
and certification. Through accreditation, activities are regularly audited by the national
the accreditation authority with regard to, among other things, competence, impartiality,
organizational independence and quality system.

ECGT requires that sustainability labels be monitored by independent verifiers, but
The directive does not specify in detail how this independence should be assessed or organised. SWETIC
therefore believes that accreditation should be recognized as an established basis for demonstrating that the requirements for
competence, impartiality and independence are met.

Within the accredited system there are already international standards that regulate these
issues. For example, ISO/IEC 17029 already specifies requirements for competence, impartiality and
independence of validation and verification bodies and thus constitutes an established basis for
to assess the requirements for independence in the implementation of ECGT.

Swedish authorities should apply a function-based approach where legal, organizational
or functional separation may meet the requirements of independence, provided that the relevant
accreditation standards are followed. This should also be able to include companies within the same group,
provided that the activities meet the requirements of impartiality and independence as
follows from the accreditation.

A harmonized implementation

A uniform implementation of the ECGT is important for the functioning of the internal market. If
Member States develop different national interpretations of the independence requirements, risking
companies have to face different regulations in different markets. This creates uncertainty, makes it difficult
cross-border activities and reduces the value of the common European
the accreditation structure.

Sweden should therefore work towards a harmonised implementation where accreditation and
independent third-party assessment is used as established tools to ensure
competence, impartiality and credibility.

The upcoming Green Claims regulations are expected to entail additional requirements for verification of
environmental claims. An implementation of ECGT that builds on the established
The European quality infrastructure therefore creates good conditions for future developments.
EU regulation.

SWETIC recommends

SWETIC urges the government and relevant authorities to:

• based on the established European accreditation scheme and relevant
  international standards, such as ISO/IEC 17029, in the assessment of verifiers
  competence, impartiality and independence within the framework of ECGT,
• clarify that functional, organizational and legal separation can meet the requirements of
  independence when relevant accreditation standards are followed,
• work towards a harmonised application of ECGT within the EU,
• involve SWETIC, Swedac and other relevant actors in the continued
  implementation and in the development of national guidance.

The implementation of ECGT is an opportunity to strengthen consumer confidence in environmental and sustainability claims. SWETIC looks forward to continued dialogue with the government and
relevant authorities on how the implementation of ECGT can be designed in a way that strengthens
consumer confidence while also taking advantage of the established European
the quality infrastructure.