Why this matters
German rules on environmental and sustainability claims become stricter on 27 September 2026. They affect not only packaging but also shop copy, product names, social media, images, labels, and statements about the whole business. Small sellers should review their communication now before old wording continues across several channels.
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Create start planWhat changes on 27 September 2026
Germany has transposed EU Directive 2024/825 into the Act Against Unfair Competition. The new provisions clarify when environmental claims are misleading and add practices that are always prohibited in consumer-facing commercial communication.
An environmental claim can arise from text, imagery, symbols, colours, product names, brand names, or company names. Searching only for words such as ‘green’ is therefore not enough. Leaves, nature imagery, or a self-created badge can combine to convey an environmental message.
The rules concern commercial communication to consumers. B2B marketing is not automatically free from misleading-advertising and competition rules, but it requires a separate assessment.
Generic language needs exceptionally strong support
Generic statements such as ‘environmentally friendly’, ‘eco’, ‘green’, ‘climate friendly’, ‘biodegradable’, and similar broad terms become prohibited where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.
A statement is not treated as merely generic when its concrete meaning is explained clearly and prominently on the same medium. For example, ‘environmentally friendly packaging’ might be replaced by the narrower statement ‘shipping box contains 80% recycled fibre’ if the measurement, reference unit, and evidence are sound.
Specific does not automatically mean lawful. A precise percentage must still be true, current, understandable, and not misleading for the purchasing decision.
Do not turn one improvement into a whole-product claim
An environmental claim about an entire product or business becomes prohibited when it actually concerns only one aspect or an unrepresentative activity. Recycled shipping paper does not automatically make the product or the whole shop sustainable.
State the subject and boundary visibly: material, packaging, production step, shipping, product variant, period, or location. The broader the claim, the broader the evidence needs to be.
Comparisons also need a traceable basis. ‘30% less material’ should reveal compared with what, for which unit, over which period, and using which data.
Carbon neutrality through offsetting and self-created labels
Claiming that a product has a neutral, reduced, or positive climate impact on the basis of greenhouse-gas offsetting becomes an always-prohibited practice. Carbon credits cannot be used to attribute climate neutrality to the advertised product itself.
Sustainability labels may only be displayed when established by a public authority or based on an appropriate certification scheme. A self-designed ‘Eco Choice’ badge without independent certification is therefore particularly risky.
Check icons supplied by manufacturers, print-on-demand services, and packaging vendors too. Receiving a logo in a product file proves neither permission to use it nor the certification basis.
Future targets need a verifiable plan
Statements such as ‘plastic-free by 2030’ or ‘we will become climate-neutral’ cannot be mere intentions. Future environmental performance claims require clear, objective, publicly available, and verifiable commitments in a detailed and realistic implementation plan with measurable, time-bound targets.
Progress must be verified regularly by an independent expert and the findings made available to consumers. For a small business, communicating a narrow improvement already achieved is often safer than publishing a large distant target without a reliable process.
Record the owner, data source, baseline, target, deadline, and update schedule for every future claim. If the plan cannot be maintained, the claim should not remain online indefinitely.
How to run a claims audit
First list every public touchpoint: product page, marketplace listing, packaging, label, newsletter, profile bio, advert, social post, image copy, company name, and badge. Old templates and automated feeds are easy to miss.
For each claim, record the exact wording, subject, likely consumer impression, evidence, evidence date, and responsible person. Then decide whether to remove, narrow, substantiate, or obtain specialist review.
Keep evidence so marketing and customer service can explain the same statement consistently. A footnote behind a broad headline does not automatically correct an overall misleading impression.
Quick checklist
- List your website, shop, listings, packaging, social media, adverts, and templates.
- Mark written, visual, and symbolic environmental claims.
- Identify the product, aspect, period, and comparison basis for each claim.
- Remove generic terms or explain them concretely on the same medium.
- Support percentages, materials, and origin statements with current data.
- Check product-level climate-neutral claims for an offsetting basis.
- Verify every sustainability label against a public basis or certification scheme.
- Use future claims only with a realistic plan, targets, and independent monitoring.
- Do not copy supplier claims without checking the evidence and usage rights.
- Roll out changes across all channels by 27 September 2026.
Common mistakes
- Treating ‘sustainable’ or ‘environmentally friendly’ as harmless marketing language.
- Hiding the concrete explanation behind an inconspicuous link.
- Turning recycled packaging into a claim about the entire product.
- Calling a product climate-neutral solely because offsets were purchased.
- Creating a green label without a certification scheme.
- Publishing future targets without a baseline, timeline, resources, and independent review.
- Copying supplier claims without checking evidence, scope, and currency.
Frequently asked questions
Are words such as ‘sustainable’ completely banned from September 2026?
No, but broad statements become demanding. A generic environmental claim needs relevant recognised excellent environmental performance, while a concrete meaning can be explained clearly and prominently on the same medium. It must still be true and substantiated.
Can I say that my packaging contains recycled material?
A specific, accurate, and substantiated material statement may be possible. State the share, subject, and measurement basis where appropriate, and do not turn it into a claim about the whole product or business without evidence.
Is a supplier certificate enough?
It can be important evidence, but it must match the product, material, period, claim, and your supply chain. Also check validity, certification scope, and whether you are entitled to use the label or statement.
What this guide can and cannot do
This guide helps with
- sort claims into generic, specific, comparative, future-facing, and label-based categories
- translate vague wording into narrower evidence questions
- prepare a claims register with evidence, date, and responsible person
This guide does not replace
- guarantee the competition-law compliance of an advertising claim
- verify measurement data, certificates, or supplier evidence
- replace specialist review of packaging, advertising, or a brand name