Starting on September 27, 2026, Germany will enforce new regulations that require companies using sustainability labels and certification schemes to align with updated 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 revised rules introduce more stringent criteria for sustainability labels and employer seals, especially those utilized in marketing and recruitment efforts.
The new regulations stipulate that labels not grounded in recognized certification systems or not established by public authorities may be subject to limitations. This encompasses not only environmental claims but also extends to social criteria such as workplace conditions, employee satisfaction, diversity, and fairness, contingent upon the nature of the seal. For a certification scheme to be deemed valid, it must fulfill several conditions, including transparent documentation, publicly accessible criteria, equal access for organizations, and independent third-party verification.
These rules aim to ensure that companies’ seals are backed by clear methodologies, thorough audits, and reliable evaluation processes. The regulation also has implications for international companies, including those outside Germany, if they use sustainability or employer seals when addressing German customers, employees, or job seekers. It is advisable for these businesses to scrutinize their certification providers, documentation, and verification methods ahead of the regulation’s enactment.
The focus of the updated rules shifts from merely assessing whether a claim is misleading to evaluating the credibility and independent verification of the certification system behind the claim. Organizations that maintain transparent certification processes might gain increased trust, while those relying on unsupported marketing labels could encounter legal challenges. Industry experts suggest that companies prepare by reviewing certification criteria, maintaining evidence of evaluation procedures, and ensuring all supporting documents are readily available. Legal guidance is also recommended for specific compliance questions related to competition law.
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