On 27 September 2026 the EmpCo Directive (EU 2024/825) came into force across the EU. Anyone who has not adapted their advertising by this date now runs measurable risks day after day — fines, cease-and-desist letters and association lawsuits.
The good news: every mid-sized company can manage a structured catch-up in 14 days. This page provides the complete plan, the risks in order of likelihood, and the most important immediate measures.
As of 27 September 2026, the per-se prohibitions laid down in the EmpCo Directive (EU 2024/825) are directly applicable law in all EU member states. In Germany the directive was transposed into national law via the 2026 UWG amendment. This means: terms such as “climate-neutral”, “CO2-neutral”, “environmentally friendly”, “green” or “sustainable” have been categorically prohibited since this deadline unless backed by concrete, verifiable and published evidence.
There is no transition period. Anyone who has missed the deadline is not in a “tolerance phase” — but in a phase of heightened attention from authorities, associations and competitors. The Wettbewerbszentrale has announced that it will screen systematically in the first 90 days after the deadline.
From 27 September 2026, the German Federal Office of Consumer Protection and Food Safety (BVL) may impose fines of up to 4 percent of global annual turnover. The first proceedings are expected for Q4 2026.
Deutsche Umwelthilfe and the Wettbewerbszentrale have announced systematic litigation from the deadline onwards. Amounts in dispute are typically between 30,000 and 250,000 euros per term.
Per-se prohibited terms can be detected automatically. Competitors are already using this actively to weaken rivals in a targeted way — typical legal costs of 1,500 to 5,000 euros per cease-and-desist letter.
A realistic clean-up of a mid-sized company website (100 to 500 subpages) takes 10 to 14 days. Anyone who does not start now risks a Q4 full of fires to put out.
This plan is designed for mid-sized companies with 100 to 500 web subpages. For group structures or a high diversity of brands the time required doubles — so start correspondingly earlier.
Automated crawl of all domains and subdomains. Output: a list of all hits with per-se classification.
Split findings into three categories: remove immediately, evidence required, uncritical. Assign an owner per term.
Rewrite texts, replace images, halt packaging mock-ups. Document every change with versioning.
One evidence dossier per remaining environmental claim: methodology, external certificates, back-calculation.
Compliance report via independent review. Counter-signed by management. Monitoring routine from day 15.
Three measures you can implement within the next two hours — and which already cut the biggest risk in half.
The complete 14-day plan to print out, including a responsibility matrix, an evidence-dossier template and a sign-off protocol for management.
Download PDFFree scan in under 30 seconds. We show you per-se breaches, critical terms and concrete rewording suggestions.
