„Low-CO₂"

What does it mean?

'Low-CO₂' is a relative claim and therefore requires clear substantiation in order not to violate § 5 UWG. The EmpCo Directive (EU 2024/825) tightens the requirements for such comparative statements. Annex I No. 4a UCPD as amended by EmpCo prohibits misleading comparative statements without a concrete comparative basis. It is not sufficient merely to speak of 'low-CO₂' products; instead, a clear reference value must be stated, for example the industry average or the emissions of a predecessor model, including source citation. The boundary of the assessment (Scope 1-3) must also be transparently disclosed in order to enable a comprehensive evaluation.

Typical phrasings

• 'Low-CO₂ production'
• 'Manufactured with particularly low CO₂'
• 'Our product is low-CO₂'
• 'Reduced CO₂ emissions'

What you can write instead

Required evidence

• Industry benchmark with clear source (e.g. IFEU, Öko-Institut)
• Life cycle analysis (LCA) according to ISO 14067
• Scope 1-3 accounting of CO₂ emissions