Stricter rules for environmental claims will apply from 27 September 2026. General claims such as “environmentally friendly”, “green” or “climate neutral” will often be prohibited if they are not supported by a specific and verifiable explanation. Businesses should therefore review their websites, online shops, social media, quotations and packaging, and amend or remove unsupported claims.

What will change for environmental claims in 2026?

The new rules cover commercial environmental claims about goods, services and entire businesses. It does not matter whether the claim appears on packaging, a website or a social network.

Germany has implemented EU Directive 2024/825 through measures including the Drittes Gesetz zur Änderung des Gesetzes gegen den unlauteren Wettbewerb (Third Act Amending the Act Against Unfair Competition). According to the Bundesregierung (Federal Government), the new provisions apply from 27 September 2026.

The specific prohibitions in the Directive concern commercial practices aimed at consumers. However, this does not mean that purely commercial communication between businesses is automatically unproblematic. The general rules of the Gesetz gegen den unlauteren Wettbewerb (Act Against Unfair Competition), abbreviated to UWG, continue to apply and prohibit misleading advertising.

Under EU Directive 2024/825, claims about services and an entire business are also covered. A cleaning company, restaurant or mail-order retailer must therefore review not only labels, but also service pages, posts, advertisements, quotation templates and signatures.

Which environmental terms will be problematic in future?

General environmental claims are prohibited unless the business can demonstrate recognised excellent environmental performance. This includes terms such as “environmentally friendly”, “green”, “climate friendly”, “ecological” and “biodegradable”.

A business does not demonstrate excellent environmental performance simply because it uses less paper or has changed some of its packaging. EU Directive 2024/825 requires performance that complies with recognised environmental labels, schemes under ISO 14024 or other relevant European Union requirements.

The scope of a claim must also be accurate. Advertising must not give the impression that an entire business operates sustainably if the improvement relates only to the electricity used at one site or to a single item of packaging.

A specific claim may, however, be permitted if it is clear, verifiable and explained directly in the same medium. Instead of “produced in a climate-friendly way”, for example, the following wording could be used: “100 per cent of the energy used for this packaging comes from renewable sources.” The business must have suitable evidence to support this claim.

Using a general term on the home page and providing an explanation on a difficult-to-find subpage is risky. The clarification should appear directly alongside the claim, for example in the same quotation, on the same product page or in the same post.

Can a business still advertise climate neutrality?

A product must not be advertised as “climate neutral” or as having reduced emissions if this characteristic is based solely on the purchase of CO₂ certificates or other offsets. The offsetting takes place outside the value chain of the advertised product.

Businesses can continue to provide factual information about climate protection projects, calculated emissions or purchased certificates. They should state precisely what was calculated, the period covered by the calculation and which emissions were included.

For example, “climate-neutral delivery” would be problematic if the transport continues to produce the same emissions and these are merely offset on paper. A more limited claim such as “We calculated delivery emissions for 2025 using method X and purchased certificates for the amount identified” describes the process more accurately, but does not prove that delivery is emissions neutral.

Which environmental labels may still be used?

A business may use its own sustainability labels only if they have been established by a public authority or are based on a certification scheme with independent monitoring. A self-designed green symbol with claims such as “ecologically verified” is not sufficient.

The Umweltbundesamt (German Environment Agency) cites the Blauer Engel (Blue Angel), the EU Ecolabel and environmental labels under ISO 14024 as examples of recognised schemes. A certification scheme must include transparent conditions and independent third-party assessment, among other requirements.

For every label used, check who awarded it, which criteria apply and how long the certification remains valid. Symbols provided by suppliers should not be added to your own online shop or quotations without first being checked.

How should businesses review their environmental claims now?

Start by compiling a complete inventory of all publicly visible claims and claims that are sent out regularly. Each instance should then be supported with evidence, made more specific or removed.

A practical checklist should include at least:

For each claim, record the exact wording, the medium, the person responsible and any available evidence. For figures, the calculation method, reference period and scope should also be documented. A statement such as “30 per cent less plastic”, for example, needs a verifiable comparison figure and a specified baseline year.

For internal planning, businesses could complete the inventory by the end of June 2026, make revisions in July and August, and publish amended content before 27 September 2026. These dates are organisational recommendations. Only 27 September 2026 is the statutory deadline.

Where many channels are involved, a central list of approved claims and supporting evidence can help. As part of consultancy on marketing, visibility and ongoing content, businesses can also define who reviews new claims and how changes are documented. ibx company advises small and medium-sized businesses in Hannover and the surrounding region on implementing this process in a structured way.

What are the possible consequences of prohibited claims?

Breaches can result in formal warning letters and claims for injunctions. Subject to the statutory requirements, competitors may also claim damages, while qualified associations can pursue injunctions in particular.

For certain widespread infringements within the European Union, the Gesetz gegen den unlauteren Wettbewerb provides for fines of up to 50,000 euros. For businesses with annual turnover exceeding 1.25 million euros, fines of up to 4 per cent of annual turnover are possible. If turnover cannot be established, the fine can be up to 2 million euros.

Not every imprecise statement will automatically result in such a fine. Nevertheless, an early review is worthwhile because packaging, quotation templates and scheduled posts cannot always be changed at short notice.

If you would like to review your environmental claims systematically and assign clear responsibilities, you can arrange a no-obligation initial consultation with ibx company. This provides an opportunity to identify, without obligation, which channels and templates should be reviewed first.