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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

Instead of: CO₂-neutral shipping"
Better: CO₂ emissions per shipment reduced by 25% (2024 vs. 2020), residual emissions offset through Gold Standard projects."
Why: EmpCo Anhang I Nr. 4a (per-se ban for 'CO₂-neutral' without reduction). § 5 UWG (misleading information).
Instead of: Green supply chain"
Better: 80% of suppliers are certified to ISO 14001, use of electric lorries for the last mile."
Why: Generic term replaced by concrete measures and certifications. § 5 UWG (misleading information).

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

ISO 14001
International standard for environmental management systems, demonstrable environmental performance.
EMAS
European environmental management system, stricter requirements than ISO 14001.
Gold Standard
Certification for high-quality CO₂ offset projects.

Relevant court rulings

BGH · I ZR 98/23 · 2024
Katjes — 'climate-neutral' without detailed disclosure of calculation methodology and offset measures is misleading pursuant to § 5 UWG. Applicable by analogy to logistics claims.

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.

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