On September 27, 2026, Germany will implement new regulations affecting sustainability labels and certification schemes, requiring companies to align their environmental, social, and employer-related seals with updated EU standards. This development is part of Germany’s Third Act Amending the Act Against Unfair Competition (UWG), which enacts the EU EmpCo Directive (2024/825). The reform aims to establish more stringent requirements for sustainability claims and certain employer seals in marketing and recruitment practices.
Under these updated regulations, labels not rooted in recognized certification systems or those not established by public authorities might face limitations. The rules extend beyond environmental claims to encompass social criteria such as workplace conditions, employee satisfaction, fairness, and diversity, contingent on the seal’s nature. A valid certification scheme must adhere to several criteria, including transparent documentation, publicly available standards, equal access for organizations, and independent third-party verification.
International companies, even those outside Germany, may be impacted if they utilize employer or sustainability seals targeting German customers, employees, or job applicants. These businesses are encouraged to evaluate their providers, documentation, and verification processes to ensure compliance before the new regulation takes effect. The updated rules pivot from merely assessing whether a claim is misleading to scrutinizing the credibility and independent verification of the certification system behind it.
Organizations with transparent and robust certification processes stand to gain increased trust, while those relying on unsupported marketing labels could face legal challenges. Industry experts advise companies to prepare by reviewing certification criteria, maintaining thorough records of evaluation procedures, and ensuring that all supporting documents are readily accessible. Furthermore, companies are urged to seek legal counsel for specific compliance concerns related to competition law.
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