Ensure legal certainty through verified labels and environmental claims, and communicate environmental commitments in a transparent and verifiable manner.
EmpCo Directive – Protection of consumers against unfair competition
Legislation and guidelines such as the EmpCo (Empowering Consumers for the Green Transition) are raising the bar for how companies communicate environmental and sustainability claims, in order to protect consumers from greenwashing and misleading claims.
General environmental claims such as ‘environmentally friendly’, ‘sustainable’ or ‘green’ will be prohibited per se from then on unless backed by outstanding environmental performance. Environmental claims must be clearly understandable, unambiguous and verifiable.
There are also new rules for private sustainability labels. Labels must be based on a transparent certification system and backed by objective third-party verification.
From 27 September 2026, the directive will become mandatory for companies.
We would be happy to assist you with the review of:
specific environmental claims (voluntary)
implementation plans for forward-looking environmental claims (mandatory)
the certification systems of private sustainability labels and their individual awarding (mandatory).
Please feel free to contact us!
Benefits of Certification
Legal certainty
Verified environmental claims reduce legal risks and help prevent potential warnings.
Security labels and seals
They ensure that your private sustainability label meets all legal requirements.
No Greenwashing
Your statements will be demonstrably clear, transparent and verifiable: they will protect your company from accusations of misleading advertising.
Credibility
They boost credibility and trust among consumers, business partners and stakeholders, and strengthen your brand reputation.
Competitive advantage
With your verified sustainability claims, you can position yourself as a transparent and responsible organisation and stand out positively from your competitors.
Under the UWG, sustainability labels are now only permitted if the environmental claims made by each label holder are based on an independent third-party audit. This means that providers are no longer permitted to verify the requirements themselves.
The underlying criteria must be documented in a clear, transparent and verifiable manner, and compliance must be demonstrated in each individual case.
Without verification, the labels are deemed unlawful and may be challenged in court under the UWG.
Under the UWG, companies may only make environmental claims that are clear, specific, verifiable and independently verifiable. Vague terms such as ‘green’ or ‘sustainable’ are not sufficient unless they are specifically defined.
Claims regarding climate neutrality or the net-zero standard must also be based on verifiable emissions reductions and must not rely solely on offsetting.
We offer you:
Objective verification of environmental and sustainability claims in accordance with the requirements of the UWG
An assessment of the validity and robustness of claims based on defined criteria and appropriate evidence
Documented audit results as a reliable basis for internal approvals and external communication
A structured, transparent and verifiable audit methodology.
We would also be happy to assist you in determining whether and to what extent an independent audit within the meaning of the UWG is appropriate or necessary for your company.
Under the UWG, additional requirements apply to forward-looking environmental statements, such as those made as part of a climate strategy:
A detailed and realistic implementation plan must be drawn up, setting out time-bound and measurable targets and the resources required to achieve them. By law, this implementation plan must be audited at regular intervals by an independent third party.
We offer you:
Objective validation of implementation plans for forward-looking environmental statements
The option to incorporate existing systems (ISO 14001, EMAS) into the audit
Documented audit results as a robust basis for internal approvals and external communication
A structured, transparent and traceable audit methodology
ISO 14001 certification guarantees you continuous improvement of your environmental performance and cost reduction through economical use of raw materials and energy