Electronics: Greenwashing Risk 2026

The electronics sector is the focus of growing consumer interest in sustainability and resource conservation. At the same time, it is particularly vulnerable to cease-and-desist orders, as complex supply chains and opaque production processes encourage greenwashing. The EU Directive 2024/825 (EmpCo) significantly tightens the requirements for communicating environmental claims from 27 September 2026. In particular, generic claims such as "environmentally friendly" or "sustainable" without concrete evidence are prohibited pursuant to Annex I No. 2 UCPD. Under Section 5 UWG and the EmpCo Directive (EU 2024/825), even seemingly harmless terms such as "natural" can be misleading if they are not covered by the actual composition of the product. This applies analogously to electronic products, where claims about "natural" materials without complete disclosure of the ingredients are inadmissible. The EmpCo Directive aims to protect consumers from misleading marketing practices and to promote transparency in the supply chain. Companies must place their environmental communication on a solid legal foundation and substantiate every claim with verifiable data, certifications or measurements. The mere statement of "energy-efficient" without stating the EU Energy Label class will no longer be permissible from 2026. Instead, manufacturers must provide concrete information about the energy consumption and environmental impact of their products. The focus is on avoiding greenwashing and promoting a genuine circular economy.