Germany is set to implement new regulations on sustainability labels and certification schemes starting on September 27, 2026. These regulations will require companies utilizing environmental, social, or employer-related seals to ensure they comply with the updated European Union standards. The initiative is part of the Third Act Amending the Act Against Unfair Competition (UWG) and aims to enforce the EU EmpCo Directive (2024/825), enhancing the credibility and transparency of marketing and recruitment activities involving sustainability claims.
Under the new framework, stricter requirements will be imposed on sustainability labels and employer seals, particularly those not based on recognized certification systems or established by public authorities. The regulations will encompass not only environmental claims but also social criteria, such as workplace conditions, employee satisfaction, fairness, and diversity, contingent on the nature of the seal. To be valid, certification schemes must adhere to several criteria, including transparent documentation, publicly accessible criteria, equal access for organizations, and independent third-party verification.
The changes will not only affect German-based companies but also international businesses that use employer or sustainability seals when targeting German customers, employees, or job applicants. Organizations are advised to thoroughly review their providers, documentation, and verification processes to ensure compliance ahead of the regulation’s enactment. The focus of these updated rules will shift from assessing whether a claim is misleading to scrutinizing the credibility and independent verification of the certification system that supports the claim.
Industry experts suggest that companies prepare for these changes by checking the criteria of their certifications, maintaining evidence of evaluation procedures, and ensuring all supporting documents are readily available. Transparent certification processes could enhance trust among consumers and stakeholders, while unsupported marketing labels might encounter legal challenges. Legal guidance is also recommended for businesses seeking to navigate specific compliance questions related to competition law.
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