On September 27, 2026, Germany plans to enforce new regulations on sustainability labels and certification schemes, impacting companies that utilize environmental, social, or employer-related seals. This initiative is part of the Third Act Amending the Act Against Unfair Competition (UWG), aligning with the EU EmpCo Directive (2024/825). The reform aims to establish stricter requirements for sustainability labels and employer seals, particularly those used in marketing and recruitment, ensuring they comply with updated EU standards.
The regulations impose conditions on labels not grounded in recognized certification systems or those not established by public authorities, potentially limiting their use. This includes not only environmental claims but also extends to social criteria, such as workplace conditions, employee satisfaction, fairness, and diversity, contingent upon the seal’s nature. To be deemed valid, a certification scheme must adhere to specific criteria, including transparent documentation, publicly available standards, equal access for organizations, and independent third-party verification. Companies must ensure their certifications are supported by clear methodologies, audits, and reliable evaluation processes.
These new rules may also affect international businesses, including those not based in Germany, if they use sustainability or employer seals aimed at German consumers, employees, or applicants. Companies are encouraged to review their certification providers, documentation, and verification processes well ahead of the regulation’s enforcement. The revised rules shift the emphasis from merely assessing whether a claim is misleading to scrutinizing whether the certification system supporting the claim is credible and independently verified. Firms with transparent certification processes could gain increased trust, whereas those relying on unsupported marketing labels might face legal challenges.
Industry specialists advise businesses to start preparing by examining certification criteria, maintaining evidence of their 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. This proactive approach will help organizations navigate the new regulatory landscape and maintain compliance with the forthcoming standards.
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