Since 27 September 2026, the Third Act amending the UWG of 12 February 2026 (Federal Law Gazette 2026 I No. 43) applies in its essential parts. It implements Directive (EU) 2024/825 and fundamentally changes environmental advertising.
New per se prohibitions
Towards consumers, the following are now prohibited without further assessment: sustainability labels not based on a certification scheme or established by public authorities (Annex no. 2a); generic environmental claims without recognised excellent environmental performance (no. 4a); claims about the whole product that concern only one aspect (no. 4b); climate neutrality based on offsetting (no. 4c); presenting legal requirements as a distinctive feature (no. 10a); misleading claims on durability, reparability and software updates (no. 23d).
Future claims need a plan
Claims about future environmental performance (“climate neutral by 2035”) are permitted only with clear, public and verifiable commitments in a realistic implementation plan, regularly monitored by an independent expert.
What to do
Review packaging, websites, social media and sales materials for generic terms, own labels and offset claims. Specific, substantiated statements remain permitted.
More: Green claims
