Germany is set to implement new regulations on sustainability labels and certification schemes starting September 27, 2026. This move mandates companies utilizing environmental, social, or employer-related seals to align with updated EU standards. The changes are part of Germany’s Third Act Amending the Act Against Unfair Competition (UWG) and aim to enforce the EU EmpCo Directive (2024/825). The reform is designed to tighten requirements on sustainability labels and employer seals used in marketing and recruitment efforts.
The revised framework stipulates that labels not grounded in recognized certification systems or those not established by public authorities could face limitations. This regulation extends beyond environmental claims to potentially include social criteria such as workplace conditions, employee satisfaction, fairness, and diversity, depending on the seal’s nature. A valid certification scheme must adhere to several conditions like transparent documentation, publicly accessible criteria, equal opportunity for organizations, and independent third-party verification.
International companies, even those based outside Germany, could be affected by this regulation if they employ employer or sustainability seals to engage with German customers, employees, or job applicants. Businesses using such certifications are encouraged to reassess their providers, documentation, and verification methods well before the regulation takes effect. The updated rules shift the emphasis from merely assessing whether a claim is misleading to evaluating the credibility and independent verification of the certification system behind the claim.
Organizations that maintain transparent certification processes stand to gain from increased trust, whereas marketing labels lacking support could encounter legal issues. Industry experts advise companies to prepare by verifying certification criteria, maintaining documentation of evaluation procedures, and ensuring all supporting documents are readily accessible. Additionally, seeking legal counsel for specific compliance queries related to competition law is recommended for companies navigating these new requirements.
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