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Printing & Publishing: Greenwashing Risk 2026

The printing and publishing industry is in the focus of growing environmental awareness and is therefore particularly at risk of warnings. Customers increasingly expect sustainable printed products and transparent production processes. The EU Directive 2024/825 (EmpCo) tightens the requirements for the communication of environmental information from 27 September 2026 and in particular prohibits generic claims. The BGH judgement of 27 June 2024 (I ZR 98/23 – Katjes) has already clarified that the use of "climate-neutral" without detailed disclosure of the CO2 calculation and compensation methods is misleading. This case law is analogously applicable to the printing and publishing industry. From 2026, transparently documented offsetting will also no longer be sufficient to advertise "climate-neutral". Claims such as "environmentally friendly printing inks" or "sustainable paper" without concrete certifications or proof are particularly critical. Printing companies and publishers must review their communication and ensure that they comply with the requirements of EmpCo and UWG. A transparent presentation of environmental performance, based on recognised standards and certificates, is the key to warning-proof and credible marketing.

Typical claims in Printing & Publishing

  • „climate-neutral printing"
  • „environmentally friendly printing inks"
  • „sustainable paper"
  • „CO2-neutral offset printing"
  • „resource-conserving production"
  • „environmentally friendly packaging"
  • „circular economy"

Concrete examples (red/amber)

  • "Climate-neutrally printed brochure" without detailed disclosure of compensation methods.
  • "Environmentally friendly printing inks" without specification of certifications such as Cradle to Cradle.
  • "Sustainable paper" without proof of FSC or PEFC certification.

EmpCo-compliant alternatives

Instead of: „Climate-neutrally printed brochure"
Better: „CO2 footprint of the brochure amounts to X kg, compensated through Gold Standard projects in Y."
Why: EmpCo Annex I No. 4a prohibits the use of "climate-neutral" without detailed disclosure and transparent compensation.
Instead of: „Environmentally friendly printing inks"
Better: „Printing inks Cradle to Cradle Certified™ Bronze Level"
Why: Generic claim replaced by concrete certification.

Recommendations

  • Use of FSC or PEFC certified paper with licence number.
  • Use of printing inks with Cradle to Cradle certification and specification of certificate level.
  • Transparent communication of the CO2 footprint of the printing process (Scope 1+2) and compensation measures (Gold Standard, VCS).
  • Use of the EU Ecolabel for printed products, provided the criteria are met.
  • Documentation and disclosure of the origin of paper and printing inks.
  • Avoidance of generic claims such as "environmentally friendly" and instead naming concrete facts and certifications.

Recognised certificates

FSC
Forest Stewardship Council – certification for sustainable forestry.
PEFC
Programme for the Endorsement of Forest Certification – alternative to FSC, also for sustainable forestry.
Cradle to Cradle
Certification for products that can be recycled in a closed loop.
EU Ecolabel
EU-wide environmental label for products and services with low environmental impact.
Gold Standard
Certification standard for high-quality CO2 compensation projects.
VCS
Verified Carbon Standard – another internationally recognised standard for CO2 compensation projects.

Relevant court rulings

BGH · I ZR 98/23 · 2024
Katjes – "climate-neutral" without detailed disclosure of CO2 calculation and compensation methods is misleading pursuant to § 5 UWG.

Frequently asked questions

What does EmpCo mean for printing companies?

From 27.09.2026, EmpCo prohibits generic claims about environmental friendliness without proof (Annex I No. 2 UCPD) and places "climate-neutral" under stricter conditions (Annex I No. 4a).

Which certificates are relevant for printing companies?

FSC and PEFC for paper, Cradle to Cradle for printing inks and EU Ecolabel for printed products are important certifications to credibly communicate sustainability aspects.

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