Greenwashing and legal guarantee: what changes for businesses in Belgium from 27 September 2026?

The Belgian Act of 22 July 2026 transposing Directive (EU) 2024/825 “Empowering Consumers for the Green Transition” entered into force on 27 September 2026. Its objectives are twofold: to strengthen the fight against greenwashing and to improve consumer information about the legal guarantee before a contract is concluded.

1. Expansion of Unfair Commercial Practices Rules

The reform broadens the scope of unfair commercial practices.

Consumers must not be misled about the main characteristics of a product. Those characteristics now expressly include environmental or social characteristics as well as circularity aspects, such as durability, reparability and recyclability. 

Twelve new practices were added to the blacklist of misleading commercial practices. From now on, businesses in Belgium will not be allowed:

• to make generic environmental claims. Stating that a product or service is ECO FRIENDLY will only be allowed if the trader can demonstrate a recognised excellent environmental track record;
• to display a sustainability label, unless it is based on a private or public certification scheme;
• to make an environmental claim about the entire product or an entire business when it concerns only a particular aspect of the product or the business;
• to claim that a product has a neutral or positive environmental impact in terms of greenhouse gas emissions if this impact is made on the basis of greenhouse gas emissions offsetting;
• to falsely claim that a product is durable in terms of its longevity and strength;
• to present a product as repairable when it is not;
• to persuade consumers to replace or replenish consumables sooner than technically necessary;
• (…). 

2. More pre-contractual information before the sale

The reform significantly expands the pre-contractual information requirements under the Belgian Code of Economic Law. The aim is to enable consumers to compare products more easily in terms of durability, reparability and longevity before making a purchase. 

These new obligations will apply not only to in-store sales but also to distance contracts and off-premises contracts. 

Legal guarantee of conformity: greater visibility

Businesses will now be required to prominently display evidence of the legal guarantee of conformity and its main elements through a harmonised notice established at EU level. This information will need to be displayed more visibly both in physical stores and online. 

Software updates

For goods with digital elements, digital content and digital services, businesses will have to inform consumers of the minimum period during which the manufacturer undertakes to provide software updates. 

Reparability and availability of spare parts

Consumers must be informed:

• of the reparability score that exists at EU level for mobile phones, laptops and tumble dryers (there is already a Belgian reparability score for dishwashers, vacuum cleaners, high-pressure cleaners, lawn mowers and laptops without touchscreens (link));
• of the availability of spare parts, their estimated cost, ordering procedures, the availability of repair instructions and any repair restrictions. 

This enhanced transparency is intended to promote more sustainable consumption and encourage repair rather than replacement. 

Commercial guarantee of durability

Where a manufacturer offers a commercial guarantee of durability at no additional cost, covering the entire product for a period exceeding two years, and makes that information available to the trader, information that the product benefits from such a guarantee, its duration and a reminder of the legal guarantee of conformity must be communicated to consumers through a harmonised label.