Germany is set to implement new regulations on sustainability labels and certification schemes starting September 27, 2026. This move is part of the Third Act Amending the Act Against Unfair Competition (UWG), aimed at aligning with the EU EmpCo Directive (2024/825). The updated rules will impose more stringent requirements on companies that utilize environmental, social, or employer-related seals, with a focus on ensuring compliance with revised European Union standards.
Under this new framework, sustainability labels that are not backed by recognized certification systems or established by public authorities could face significant restrictions. These rules extend beyond environmental claims to potentially include social criteria such as workplace conditions, employee satisfaction, fairness, and diversity, contingent on the seal’s nature. To be considered valid, certification schemes must fulfill several criteria, including transparent documentation, publicly accessible criteria, equal opportunity for organizations, and independent third-party verification.
The upcoming regulations may also impact international businesses, including those outside Germany, if they employ sustainability or employer seals to appeal to German customers, employees, or job applicants. Companies are encouraged to assess their certification providers, documentation, and verification methods in preparation for the regulation’s enforcement. This shift places a greater emphasis on the credibility and independent verification of the certification system behind the claims, rather than merely determining if a claim is misleading.
Organizations that maintain transparent certification processes stand to gain increased trust, while those relying on unsupported marketing labels could encounter legal challenges. Industry experts advise businesses to examine certification criteria, document evaluation procedures, and ensure that all supporting documents are readily available. Additionally, seeking legal guidance for specific compliance issues related to competition law is recommended.
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