Care & Social Services: Greenwashing Risk 2026

The care and social services sector is the focus of growing public and legal attention with regard to sustainability. From 27 September 2026, EU Directive 2024/825 (EmpCo) tightens the requirements for transparency and substantiation of environmental and social claims. In particular, generic claims such as "sustainable care" or "environmentally friendly care home" are inadmissible without concrete evidence (Annex I No. 2 UCPD). The judgement of the BGH I ZR 98/23 (Katjes) makes clear that even in the food sector – and by analogy for other sectors – the mere use of terms such as "climate-neutral" without detailed disclosure of the calculation methodology and offsetting measures is misleading. For care facilities, this means that pure image campaigns without substantial measures and their transparent communication are no longer sufficient. The risks of warnings from competitors or consumer protection organisations are high. Particularly critical are statements about climate neutrality that are frequently made through CO2 offsetting without simultaneous reduction of emissions (Annex I No. 4a UCPD). The sector is also characterised by high resource consumption (energy, water, materials) and a large number of employees, which underlines the necessity of a holistic sustainability concept. Legally compliant communication requires the documentation and disclosure of concrete measures that demonstrably contribute to a reduction of environmental impacts and to the improvement of social conditions. This includes, for example, the use of renewable energies, the implementation of an environmental management system (ISO 14001, EMAS), the use of environmentally friendly care products and the promotion of fair working conditions.