Warning Wave 2025: Greenwashing in the Crosshairs of the Consumer Advice Centre

From 27 September 2026, EU Directive 2024/825 (EmpCo) will come into full force, tightening the rules for environmental claims in corporate communications. This is already leading to increased scrutiny by consumer organisations and a corresponding wave of warnings.

Increasing Warnings from the Consumer Advice Centre

The Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband (vzbv)) already recorded a significant increase in warnings in the area of greenwashing in 2025. While the exact figures may vary, the trend signals increased control of environmental claims. The focus is on companies that make misleading or unsubstantiated claims about the environmental friendliness of their products or services. The areas of food, fashion and energy are particularly affected.

Risky Environmental Claims After EmpCo

The EmpCo Directive prohibits certain statements per se and sets high requirements for the substantiation of others. Particularly critical are:

* **Climate neutrality with offsetting:** As confirmed by the Bundesgerichtshof (BGH, Germany's Federal Court of Justice) in the Katjes ruling (I ZR 98/23) of 27 June 2024, claims of climate neutrality based on carbon offsetting are fundamentally inadmissible. * **Generic environmental terms:** Terms such as “sustainable”, “environmentally friendly” or “green” must not be used without concrete, measurable evidence. * **Own sustainability seals:** Companies must not use their own seals or labels that are not secured by an independent, external certification system.

Statements about the regional origin of products can also be problematic if they cannot be substantiated by appropriate certificates or evidence. Under Section 5 UWG and the EmpCo Directive (EU 2024/825), clear and comprehensible information on origin is required.

Concrete Recommendations for Action for Companies

To minimise the risk of warnings, companies should take the following measures:

1. **Inventory:** Review all marketing materials, website content and product descriptions for potentially problematic environmental claims. 2. **Collect evidence:** Ensure that all environmental claims are substantiated by recognised certificates (e.g. EU-Bio, Fairtrade, Bluesign, FSC) or other verifiable evidence. 3. **Adjust wording:** Avoid vague or general statements. Instead, use concrete and measurable information. 4. **Legal advice:** Have your marketing materials checked by an experienced lawyer to ensure that they comply with the requirements of the EmpCo Directive. 5. **Monitoring:** Regularly monitor the activities of consumer organisations and adjust your communication accordingly.

Early adaptation to the new regulations is crucial to avoid costly warnings and reputational damage. A proactive compliance approach is significantly cheaper than defending legal disputes.