Germany is set to implement new regulations concerning sustainability labels and certification schemes starting September 27, 2026. These regulations will require companies that utilize environmental, social, or employer-related seals to ensure their compliance aligns with the updated standards set by the European Union. This change comes as part of Germany’s Third Act Amending the Act Against Unfair Competition (UWG), which serves to put into action the EU EmpCo Directive (2024/825). The reform is aimed at establishing stricter guidelines for sustainability labels and certain employer seals, particularly those used in marketing and recruitment.
The new framework will impose restrictions on labels that are not grounded in recognized certification systems or created by public authorities. This update extends beyond environmental claims to encompass social criteria such as workplace conditions, employee satisfaction, fairness, and diversity, depending on the specific nature of the seal in question. In order for a certification scheme to be considered valid, it must satisfy several requirements. These include maintaining transparent documentation, having publicly available criteria, ensuring equal access for all organizations, and undergoing independent third-party verification.
International companies, including those that are not based in Germany, may also be impacted by these regulations if they use employer or sustainability seals in their efforts to reach German consumers, employees, or job applicants. Businesses employing such certifications are advised to scrutinize their providers, documentation, and verification procedures well in advance of the new rules taking effect. The updated regulations shift the focus from merely assessing the potential misleading nature of a claim to evaluating the credibility and independent verification of the certification system that supports the claim.
Organizations that maintain transparent certification processes could see a boost in trust, whereas marketing labels lacking support might encounter legal challenges. Experts within the industry suggest that companies prepare by reviewing certification criteria, keeping evidence of their evaluation procedures, and ensuring all supporting documents are readily accessible. Furthermore, seeking legal counsel for specific compliance questions related to competition law is recommended to ensure thorough preparation.
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