The introduction of the EU’s Empowering Consumers for the Green Transition (ECGT) Directive means some changes to how the Butterfly Mark is assessed and certified. While the transition will strengthen the credibility of your certification, we know you may have questions about what it means for your business. Below you’ll find answers to the most common questions about the transition, what you need to do, and how we’ll support you every step of the way.
FAQs
What is the ECGT Directive, and why does it matter?
The Empowering Consumers for the Green Transition (ECGT) Directive comes into force on 27 September 2026. It applies to businesses that sell or market goods to consumers in the EU, either directly or indirectly. The Directive is designed to improve transparency around sustainability claims. It bans vague environmental terms such as “eco-friendly” or “sustainable” unless they can be substantiated with verified evidence. It also requires sustainability certifications used in consumer communications to be independently verified by an accredited third party. This is a positive step for the industry. It raises the standard for sustainability certifications, strengthens consumer trust, and makes the Butterfly Mark an even more meaningful and credible mark of achievement.
What do I need to do?
There are just two actions required from you initially:
This commitment allows you to continue using the Butterfly Mark during the transition period.
Will Positive Luxury support us through the transition?
Absolutely, your Account Manager will guide you through every step of the process, identify any evidence gaps, support you with the third-party verification, and ensure your transition is as smooth as possible. For now, all you need to do is meet with your Account Manager and return your signed commitment letter. We’ll take it from there.
What happens after I submit my commitment?
Your Account Manager will compare your existing assessment against the new ESG+2.1 requirements and identify whether any additional evidence is needed. In most cases, we expect any additional evidence requirements to be minimal.
You’ll have up to 15 months to provide anything that’s required.
Can I keep using my Butterfly Mark while the transition is underway?
Yes, just confirm your commitment to the transition using the templated letter that will be supplied to you, and continue using the Butterfly Mark without interruption.
Will I need to complete a full recertification?
No, as an existing Butterfly Mark holder, you’ve already completed most of the work required. Your existing assessment responses and supporting evidence will carry forward wherever possible. Your account manager will identify any gaps and support you through the transition, making the process as straightforward as possible.
Do I need to update how I use the Butterfly Mark?
Yes, there will be some changes in how you use your Butterfly Mark and updated Brand Guidelines will be shared shortly. To ensure consumers are able to easily and quickly find out more about your certification, will be recommending that your Butterfly Mark:
What are the key dates?
By 27 September 2026
By 27 September 2027
What are the benefits of these changes?
The transition will:
Will there be a cost?
Control Union will charge a verification fee to independently review your evidence and re-issue your Butterfly Mark, which is then valid for three years. The exact fee will depend on business size, and in most cases will be between £800 and £1,600. This is one-off cost across the three-year license. Your account manager will discuss this with you.
How much work will the transition involve?
We will do the heaving lifting for you, including migrate your existing assessment to 2.1. You are already likely to be meeting most of the 21 requirements, and your account manager will identify any evidence gaps in advance so you know exactly what’s needed before the transition begins. After the transition, the majority of the community will not need to go through a full recertification process until 2030.
What happens to my Digital Butterfly Passport?
We will update it automatically before 27 September 2026 to remove your public-facing scores. You do not need to do anything. After the transition, your digital passport will be an even more powerful tool of proof.
What if I do not market to or sell into the EU?
If you are unsure whether you are impacted by the new legislation, speak to your account manager.
Do my contract terms and membership pricing remain the same?
Yes, general terms remain the same, although your next Butterfly Mark license will be for 3-years, and there will be an updated clause regarding data and third parties.
What if I have more questions?
Your account manager will be in touch shortly to arrange a catch-up in the next few weeks. In the meantime, if you have any questions, please contact your account manager.
For more information please contact your account manager or email clientsuccess@positiveluxury.com