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Automotive: Greenwashing Risk 2026

The automotive industry has been one of the most prominent examples of greenwashing since the VW diesel scandal. Under Section 5 UWG and the EmpCo Directive (EU 2024/825), even synthetic fuels (e-fuels) and hybrid drives do not justify blanket "green mobility" claims. From 27 September 2026, manufacturers must disclose the system boundary (Scope 1-3) and methodology for every CO₂ claim. Particularly sensitive: "Zero Emission" advertising for electric cars is only permissible under EU law for local driving operation — battery production belongs to the supply chain and is not emission-free.

Typical claims in Automotive

„climate-neutral mobility"
„green diesel"
„emission-free driving"
„climate-friendly car"
„CO₂-neutral drive"
„zero emission"
„sustainable SUV"
„environmentally friendly hybrid"
„green mobility transition"
„CO₂-neutral delivery"

Concrete examples (red/amber)

'Climate-neutral vehicle' through CO₂ offsetting in reforestation projects
'Zero Emission' for electric cars without consideration of battery production (Scope 3)
'CO₂-neutral drive' without life-cycle assessment
'Climate-friendly diesel' through e-fuel blending (BGH 2023)
WLTP values vs. real consumption — misleading with 'only 4.5 l/100 km'

EmpCo-compliant alternatives

Instead of: „Climate-neutral mobility"

Better: „CO₂ footprint per 100 km reduced by 67% (vs. combustion-engine predecessor model, LCA according to ISO 14067, Scope 1-3, 2024)"

Why: Vague term replaced by quantified reduction + system boundary.

Instead of: „Zero Emission electric car"

Better: „Locally emission-free in driving operation. Battery production in Sweden (Northvolt) with green electricity: 45 kg CO₂/kWh battery capacity"

Why: Separate local vs. supply chain — battery production is not emission-free.

Instead of: „Green diesel with e-fuel blending"

Better: „Diesel with 30% synthetic e-fuel from renewable electricity (RED II-compliant) — CO₂ reduction 25% vs. fossil diesel"

Why: Share + standard + reduction value quantified.

Recommendations

State complete life-cycle analysis (LCA) with system boundary Scope 1-3
WLTP consumption values transparent, plus note on real-world deviation
For electric vehicles: disclose CO₂ footprint of battery production
Quantify CO₂ reduction in production versus predecessor model
Link to CARB certification or EU type approval

Recognised certificates

EU type approval with WLTP values

Mandatory consumption and emission data for passenger car registration.

CARB ZEV

California Zero-Emission Vehicle programme, world's strictest standard for electric mobility.

Blue Angel for electric vehicles

Takes into account life cycle including battery recycling and electricity mix.

ISO 14067 (Product Carbon Footprint)

International standard for product-related carbon footprint.

GHG Protocol Corporate Standard

Scope 1-3 accounting for companies.

Frequently asked questions

Can I still advertise 'Zero Emission' for electric cars?

Only with restrictions. Permissible is 'locally emission-free in driving operation' or 'Zero Tailpipe Emissions'. 'Zero Emission' as a blanket claim is misleading under Section 5 UWG and the EmpCo Directive (EU 2024/825), as battery production and electricity mix cause CO₂ emissions.

What does WLTP mean — and why are the values misleading?

WLTP (Worldwide Harmonized Light Vehicle Test Procedure) has been the EU-mandatory test standard since 2017. Real consumption is typically 20-30% higher. Therefore: state WLTP values, but add a note that real values vary depending on driving style and conditions.

Is CO₂ offsetting sufficient for a 'climate-neutral' drive?

No, from 27.09.2026 prohibited per se under EmpCo Annex I No. 4b. Instead: show reduction pathway (e.g. 'CO₂ per vehicle reduced by X%'), offsetting only as supplement with project methodology (Gold Standard, VCS).

What must be included in an LCA (life-cycle analysis)?

According to ISO 14067: goal and scope, system boundary (Scope 1-3), functional unit (e.g. per 100 km), data sources, assumptions, results, critical review (third-party review). Without these elements, the claim is not substantiated.

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