Germany is set to implement new regulations on sustainability labels and certification schemes starting September 27, 2026, which will require companies to ensure their compliance with updated EU standards. These new rules, part of Germany’s Third Act Amending the Act Against Unfair Competition (UWG), aim to tighten requirements for sustainability and employer-related seals used in marketing and recruitment. This move is in line with the EU EmpCo Directive (2024/825) and is expected to bring about significant changes in how companies promote their environmental and social credentials.
Under the revised framework, sustainability labels that are not based on recognized certification systems or established by public authorities may face restrictions. These regulations will not only affect environmental claims but could also extend to social criteria related to workplace conditions, employee satisfaction, fairness, and diversity, depending on the type of seal. Companies will need to ensure their certifications are backed by transparent methodologies, audits, and reliable evaluation processes to remain compliant.
The updated rules emphasize the credibility of the certification systems behind claims, rather than simply assessing whether a claim is misleading. This shift could provide benefits for organizations with transparent processes, potentially increasing consumer trust, while those using unsupported marketing labels could encounter legal challenges. As a result, businesses using sustainability or employer seals, especially those targeting the German market, are encouraged to review their providers and verification processes before the regulations take effect.
Companies, including those based outside of Germany, that use these seals to appeal to German customers, employees, or applicants, should start preparing for compliance. Industry experts advise businesses to verify certification criteria, maintain evidence of evaluation procedures, and ensure all supporting documents are readily accessible. Additionally, seeking legal guidance regarding specific compliance aspects related to competition law is recommended to navigate these new requirements effectively.
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