Starting on September 27, 2026, Germany will enforce new regulations concerning sustainability labels and certification schemes, compelling companies to ensure their adherence to enhanced EU standards. This change is part of Germany’s Third Act Amending the Act Against Unfair Competition (UWG), which implements the EU EmpCo Directive (2024/825). The reform aims to tighten the criteria for sustainability labels and specific employer seals utilized in marketing and recruitment, demanding more rigorous compliance.
The updated guidelines necessitate that labels not founded on recognized certification systems or not issued by public authorities might encounter restrictions. These rules extend beyond environmental claims to encompass social criteria, including workplace conditions, employee satisfaction, fairness, and diversity, depending on the type of seal involved. A legitimate certification scheme must fulfill requirements such as transparent documentation, publicly available criteria, equal access for organizations, and independent third-party verification to be considered valid.
International companies, including those based outside Germany, could be impacted by this regulation if they employ employer or sustainability seals targeting German consumers, employees, or job applicants. Businesses using such certifications are advised to scrutinize their providers, documentation, and verification processes ahead of the regulation’s enforcement. The new rules prioritize verifying whether the certification system supporting a claim is credible and independently verified, rather than merely assessing if a claim is misleading.
Organizations that maintain transparent certification processes may see an increase in trust, while those relying on unsupported marketing labels could face legal challenges. Industry experts suggest that businesses prepare by reviewing certification criteria, maintaining evidence of evaluation procedures, and ensuring all supporting documents are accessible. Additionally, companies are encouraged to seek legal counsel to address specific compliance questions related to competition law.
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