Germany is set to implement new sustainability labeling and certification regulations on September 27, 2026. These rules will impact companies using environmental, social, or employer-related seals, requiring them to align with updated European Union (EU) standards. This change 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 tighten requirements for sustainability labels and certain employer seals utilized in marketing and recruitment.
Under the new framework, labels not rooted in recognized certification systems or established by public authorities might face usage restrictions. These rules extend beyond environmental claims to potentially cover social criteria, including workplace conditions, employee satisfaction, fairness, and diversity, depending on the seal’s nature. To be considered valid, a certification scheme must fulfill several criteria such as transparent documentation, publicly accessible criteria, equal access for organizations, and independent third-party verification. Companies must ensure their seals are backed by clear methodologies, audits, and reliable evaluation processes.
The regulation’s reach could extend to international companies, including those outside Germany, if they employ employer or sustainability seals in their efforts to attract German customers, employees, or applicants. Businesses using these certifications are urged to review their providers, documentation, and verification processes in advance of the regulation’s enforcement. The updated rules shift the emphasis from merely assessing whether a claim is misleading to evaluating the credibility and independent verification of the certification system supporting the claim.
Organizations with transparent certification processes could gain increased trust, whereas unsupported marketing labels might face legal scrutiny. Industry experts advise businesses to prepare by checking certification criteria, maintaining evidence of evaluation procedures, and ensuring that all supporting documents are accessible. Companies are also encouraged to seek legal counsel for specific compliance questions related to competition law.
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