Starting September 27, 2026, Germany will enforce new regulations affecting sustainability labels and certification schemes, compelling companies employing environmental, social, or employer-related seals to align with updated European Union standards. These changes arise from Germany’s Third Act Amending the Act Against Unfair Competition (UWG), aimed at implementing the EU EmpCo Directive (2024/825). The reform introduces more stringent criteria for sustainability labels and employer seals used in marketing and recruitment.
The updated framework stipulates that labels not grounded in recognized certification systems or those not established by public authorities may encounter restrictions. This regulation extends beyond environmental claims to potentially include social criteria like workplace conditions, employee satisfaction, fairness, and diversity, depending on the nature of the seal. Ensuring compliance involves meeting several requirements: transparent documentation, publicly available criteria, equal access for organizations, and independent third-party verification.
International companies, including those based outside Germany, could be impacted if they utilize employer or sustainability seals while targeting German customers, employees, or applicants. Consequently, businesses are advised to reassess their providers, documentation, and verification processes ahead of the regulation’s effective date. The focus of the updated rules shifts from merely evaluating if a claim is misleading to scrutinizing the credibility and independent verification of the certification system supporting the claim.
Organizations with transparent certification processes stand to gain increased trust, whereas unsupported marketing labels might face legal challenges. Industry experts suggest that businesses prepare by reviewing certification criteria, maintaining evidence of evaluation procedures, and ensuring that all supporting documents are readily accessible. Legal guidance is also recommended for addressing specific compliance questions related to competition law.
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