Germany is set to implement new regulations on sustainability labels and certification schemes from September 27, 2026, as part of its Third Act Amending the Act Against Unfair Competition (UWG). This move aligns with the EU’s EmpCo Directive (2024/825) and will demand companies using environmental, social, or employer-related seals to ensure their compliance with updated EU standards. The reform aims to impose stricter criteria on sustainability labels and certain employer seals utilized in marketing and recruitment practices.
The revised framework mandates that labels not linked to recognized certification systems or established by public authorities might face limitations. These rules extend beyond environmental claims to potentially encompass social criteria, including workplace conditions, employee satisfaction, fairness, and diversity, based on the seal’s nature. A valid certification scheme under this new system must fulfill several conditions, such as transparent documentation, publicly accessible criteria, equal access for organizations, and independent third-party verification.
International companies, including those operating outside Germany, could be impacted if they employ employer or sustainability seals in their marketing efforts targeting German consumers, employees, or job applicants. As a result, businesses are encouraged to review their certification providers, documentation, and verification processes before the new regulation becomes effective. The updated rules shift the emphasis from merely assessing whether a claim is misleading to evaluating the credibility and independent verification of the certification system supporting the claim.
Organizations with transparent certification processes might gain increased trust, while unsupported marketing labels could encounter legal challenges. Industry experts advise businesses to prepare by examining certification criteria, maintaining evidence of evaluation procedures, and ensuring all supporting documents are readily accessible. Seeking legal guidance on specific compliance issues related to competition law is also recommended.
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