PGS and sustainability labels: what Directive (EU) 2024/825 changes on 27 September 2026

Participatory Guarantee Systems appeal through their horizontal, low-cost approach. But from September 27, 2026, a sustainability label shown to consumers must rest on independent verification. A look at a legal turning point, and what it means for operators.

A new rulebook for labels

Directive (EU) 2024/825, known as "Empowering Consumers for the Green Transition," amends Directive 2005/29/EC on unfair commercial practices. Transposed by March 27, 2026 at the latest, it applies across the Union from September 27, 2026.

Its most structural contribution for our sector fits in a single sentence: displaying a sustainability label that is not based on a certification scheme, or that has not been established by public authorities, becomes an unfair commercial practice. The text then defines what qualifies as an acceptable certification scheme through several cumulative criteria: public requirements developed with stakeholders, transparent and non-discriminatory access, a procedure to withdraw the label in case of non-compliance, and above all a compliance check carried out by a party independent of both the trader and the scheme owner.

That last criterion, the independence of the verifier, is the linchpin of the whole mechanism. It is also the one on which a very popular model, the Participatory Guarantee System, stumbles by design.

The PGS openly replaces the third party with the collective

The Participatory Guarantee System (PGS) is defined as a locally focused quality assurance system that certifies producers based on the active participation of the stakeholders concerned, on a foundation of trust, networks and knowledge exchange. Assessment is carried out by peers, producers and community members, with shared decision-making power.

This is not an outside criticism; it is the model's claimed nature. The leading academic work states it plainly. As Patrick Mundler and Stéphane Bellon write in the journal Pour, PGS pursue impartiality and transparency of control like any certification process, but, unlike third-party control systems, it is social control by the collective that guarantees them. In such a system, the authors note, actors are in turn assessed and assessors.

This is where the incompatibility lies. A system in which one is alternately assessed and assessor produces trust and co-evaluation, not verification independent of the trader in the sense the directive requires.

Independence is not a regulatory novelty

One might think 2024/825 invents a constraint. It merely enshrines a long-standing principle. As far back as the EN 45011 standard, the direct ancestor of today's ISO/IEC 17065, product certification rested on four pillars: independence, competence, confidentiality and effectiveness. Accredited third-party certification has always relied on a strict separation between support, assessment and decision.

The PGS, by contrast, merges these functions within a single collective. That choice is consistent with its philosophy, but it excludes it from the field of acceptable certification schemes for a label displayed to consumers.

A precedent the organic world already knows

This reasoning is anything but theoretical. It is already at work in organic farming. In Europe, a producer relying solely on a PGS is not allowed to display the AB (organic) logo: that logo requires control by an approved certification body. So much so that the vast majority of producers involved in a participatory network such as Nature & Progrès are, in practice, doubly certified, through their participatory approach on one side and by a third-party body on the other.

In other words, European law already denies the PGS alone access to the main official sustainability label. Directive 2024/825 simply extends this logic to all sustainability labels used in B2C communication.

Where the PGS keeps its full value

It would be dishonest to conclude that the PGS has no value. On the contrary, the literature shows it is particularly suited to local initiatives, short supply chains built on direct mutual knowledge between producers and consumers, and emerging agroecology dynamics. As a tool for collective progress, knowledge sharing and local engagement, it plays a real role.

The question, then, is not whether the PGS is good or bad. It is whether it constitutes a legally acceptable basis for displaying a sustainability label to a consumer, in commerce, from September 27, 2026. On that specific ground, the answer is no.

What accredited ISO/IEC 17065 certification guarantees

Faced with this requirement, product certification issued by an accredited third-party body natively ticks the directive's boxes. Independence from the trader and the scheme owner is ensured by design. The separation between support, assessment and decision is a structural requirement of the standard. The control produces enforceable, traceable and auditable proof, not a statement of trust. Finally, impartiality is not self-proclaimed: it is overseen by accreditation itself, the mark of a trusted third party recognized at European level.

IRICE is accredited by Cofrac (accreditation no. 5-0655, certification of products, processes and services, scope available at www.cofrac.fr) under ISO/IEC 17065. This is precisely the type of framework that Directive 2024/825 makes essential for any sustainability label intended for consumers.

Are you concerned?

If you display, or plan to display, a sustainability claim or an environmental label on a product or commercial medium intended for the general public in the Union, the answer is yes. The point to check before September 27, 2026 is simple: is the control underpinning your label carried out by a party independent of you and of the scheme owner? If the answer rests on peer assessment or collective self-assessment, the label is exposed.

Take stock

IRICE supports operators in bringing their claims and labels into compliance with Directive 2024/825, on the basis of accredited third-party certification. For an admissibility diagnosis of your label, contact us.

Sources: Directive (EU) 2024/825; Directive 2005/29/EC; Regulation (EC) 765/2008; ISO/IEC 17065; P. Mundler and S. Bellon, "Participatory Guarantee Systems: an alternative to third-party certification?", journal Pour, no. 212, 2011.