Logistics: Greenwashing Risk 2026
The logistics sector will be a focus of the EmpCo Directive from 27 September 2026 and is particularly at risk of warnings. The growing importance of sustainability amongst customers is leading to increased communication of "green" services, which is often insufficiently substantiated. The BGH judgment on Katjes (I ZR 98/23) makes it clear that blanket statements such as "climate-neutral" without transparent disclosure of calculation methodology and offset measures are deemed misleading. The EmpCo Directive tightens these requirements: generic claims without recognised evidence are prohibited pursuant to Anhang I Nr. 2 UCPD. This particularly affects claims such as "green supply chain" or "climate-friendly logistics", which are inadmissible without concrete information on means of transport, supplier standards or CO₂ savings. Companies must adapt their communication and rely on transparent, verifiable statements. Calculating CO₂ emissions according to the GLEC Framework (Global Logistics Emissions Council) is an important step in creating a sound basis for communication. In addition, the disclosure of concrete reduction targets with a defined base year and the documentation of progress is essential. Certification of suppliers according to sustainability standards such as ISO 14001 or EMAS can also help to increase the credibility of statements. Those who do not meet these requirements risk warnings and damage to their image.
Typical claims in Logistics
- „CO₂-neutral shipping"
- „Green supply chain"
- „Climate-friendly logistics"
- „Low-emission transport"
- „Sustainable packaging"
Concrete examples (red/amber)
- 'CO₂-neutral shipping' through blanket offsetting without reduction targets
- 'Green supply chain' without information on means of transport or supplier standards
- 'Climate-friendly logistics' without measurable CO₂ savings or certifications
EmpCo-compliant alternatives
Recommendations
- Calculate and transparently disclose CO₂ emissions according to the GLEC Framework (Global Logistics Emissions Council) (Scope 1, 2, 3).
- Define concrete reduction targets (e.g. -30% CO₂ by 2030) with base year and document progress.
- Quantify and evidence the use of alternative drives (electric, hydrogen).
- Create supply chain transparency and have suppliers certified according to sustainability standards (e.g. ISO 14001).
- Evidence the use of recycled or biodegradable packaging materials.
Recognised certificates
Relevant court rulings
Frequently asked questions
Can I still advertise 'CO₂-neutral shipping'?
No, not in blanket terms any more. From 27.09.2026, 'CO₂-neutral' is prohibited pursuant to EmpCo Anhang I Nr. 4a. You must instead transparently disclose concrete reduction targets and offset measures.
What does the EmpCo Directive mean for my logistics claims?
The EmpCo Directive prohibits generic claims without evidence (Anhang I Nr. 2 UCPD). You must substantiate every statement with recognised certificates or measurable data in order to avoid warnings.

