Belgium

Status of the current legislative process

No draft implementation has been published yet. There are currently no further information available with regards to the timeline.

In response to a parliamentary question raised on 31 July 2025, the Minister for Employment, the Economy and Agriculture, who is responsible for transposing the Directive, announced on 21 August 2025 that the transposition process is currently underway, without specifying a timeline.

Link to the draft (if available) 

N/A

Does the implementation go beyond EmpCo requirements? 

No

Are there any comments from relevant authorities on the interpretation or enforcement of the national implementation?  

No

Will the national implementation be applied in a Business-To-Business (B2B) context? 

The EmpCo additions to the blacklist are unlikely to apply in a B2B setting, as the blacklist is also currently not applied in a B2B context.  

The blacklist of the Unfair Commercial Practices Directive is only implemented in the case of unfair commercial practices towards consumers. However, we cannot exclude that the blacklist couldn’t be used as a guideline or reference in a B2B dispute, but we are not aware of any precedents in which that would have been the case. 

Is there a green claims guide/guidance in your country? 

This Guidance document brings clarification about the current state of the legislation as regards environmental claims (available https://economie.fgov.be/sites/default/files/Files/Entreprises/Guide-pratique-Bonnes-pratiques-en-matiere-d-Allegations-environnementales.pdf). 

What are the sanctions and penalties?  

Green claims are subject to Articles VI.93 to VI.100 of the Economic Law Code (ELC) which addresses unfair commercial practices. Misleading green claims may be considered as unfair commercial practices, subject to penalties in the ranges between EUR 208 to EUR 80,000 or up to 4% of the annual turnover (if higher).

Does the national implementation answer the following questions:  

(1) whether sustainability labels can take the form of text; 
(2) whether generic environmental claims can be used or are they banned unless you have recognised excellent environmental performance; 
(3) whether GHG impact claims based on GHG offsets are banned only if offsets are the sole basis, or even if offsets and GHG reductions are combined.

N/A