From 27 September 2026, advertising using "sustainable", "environmentally friendly" or "green" will only be permitted if every claim is substantiated directly on the advertising medium with concrete evidence. This page sets out the four core principles, gives reformulation examples for four typical claims and ranks the risk per channel.
Last update: 26 May 2026
Generic terms such as "sustainable" or "environmentally friendly" must be replaced with concrete, measurable properties — e.g. "80% less water consumption in production compared with 2019".
Evidence must be accessible directly on the same web page or advertising medium — not a reference to a 200-page sustainability document, but inline links to the standard, certificate and methodology.
Anyone who actually reduces part of their emissions and offsets another part must communicate both openly. Merging the two figures is misleading.
In-house "eco" labels and self-certifications are banned from 2026 if they suggest a third-party seal. Only accredited seals are reliable (Blue Angel, EU Ecolabel, FSC, GOTS).
This is how the four most common high-risk wordings look after reformulation — substantiated, verifiable and legally compliant.
Highest risk of a cease-and-desist letter. Product copy, category pages, marketing banners and about pages are systematically screened by competition associations.
Greatly underestimated. Blanket claims in image captions or story texts are increasingly being monitored by consumer protection associations.
Long production cycles — changes require a lead time of 6–12 months. Existing stock can become a cease-and-desist trap from 27 September 2026.
Medium risk due to limited reach, but high public visibility — flawed campaigns are picked up by the trade press.
Low but steadily rising risk. Competition associations systematically subscribe to the newsletters of competing brands.
Only in combination with concrete evidence. "Sustainably produced" on its own is prohibited — "produced and certified to the GOTS standard (certificate no. XY)" is permitted. Rule of thumb: every blanket term must be backed up on the same page by a verifiable fact.
Recognised standards (ISO 14040 LCA, GHG Protocol, EN 13432, GOTS, FSC), independent certifications (Blue Angel, EU Ecolabel, Demeter, Naturland) and scientific studies with a citable source. Your own calculations without external verification are not enough.
Step 1: Identify all blanket terms. Step 2: For each term, ask — on what measurable fact is this based? Step 3: Link the fact with its source directly on the advertising medium. Step 4: External legal review before publication, ideally with a verification check (e.g. a TÜV audit or third-party assessment).
No, these terms have no direct environmental reference and do not fall under EmpCo. But if they implicitly imply environmental benefits ("regional = sustainable"), the directive applies again. The claim must then be substantiated.
For a medium-sized website with 50–100 pages, a realistic timeframe is 4–8 weeks: audit (1 week), research and gathering evidence (2–3 weeks), copy revision (1–2 weeks), legal review (1 week). For larger sites, correspondingly more.
A cross-industry guide for risk-aware communication.
50 points to reduce your exposure to cease-and-desist letters.
Over 40 terms with permitted alternatives and standard-based evidence.
Risk profiles per industry from construction to tourism.
