The End of Greenwashing? New Regulation Is Changing Sustainability Communication

Starting in September 2026, significantly stricter rules will apply to companies’ sustainability claims. What communication professionals need to know now. 

The reform of the Unfair Competition Act (Gesetz gegen den unlauteren Wettbewerb, UWG) will fundamentally change the rulebook for corporate communications in Germany as of September 27, 2026. The background is the implementation of EU Directive (EU) 2024/825 (EmpCo Directive), which aims to better protect consumers from misleading environmental claims (“greenwashing”). 

The new rules primarily target product- and service-related environmental claims directed at consumers. The requirements will become substantially stricter: 

• Broad claims such as “climate-neutral,” “environmentally friendly,” or “green” will only be permitted if they are substantiated by verifiable and recognized evidence of outstanding environmental performance (for example, established eco-labels such as the Blue Angel). 

• Product-level climate neutrality claims based solely on offsetting (e.g. certificates) will be prohibited. Companies will need to demonstrate actual CO₂ reductions; offsetting alone will no longer suffice. 

• When communicating targets such as “climate neutral by 2030,” companies must be able to substantiate these with more than aspirational statements. This requires concrete, publicly verifiable implementation plans, clear interim targets, and regular independent verification. Without such substantiation, claims risk being considered misleading. 

Enforcement could also become significantly stricter. In addition to cease-and-desist claims, companies with an annual turnover exceeding €1.25 million may face fines of up to 4% of their annual turnover in the relevant EU Member States. Reputational risks are also likely to increase, particularly through public allegations of greenwashing in traditional and social media. 

To date, enforcement has largely been driven by activist groups. Going forward, regulatory scrutiny will intensify – along with the direct responsibility of communications teams. 

Simply asking, “What are we still allowed to say?” falls short. 

The stricter rules also present an opportunity: companies that communicate their sustainability performance in a transparent and legally robust manner can credibly differentiate themselves from competitors relying on superficial claims. 

Four practical steps to take now: 

• Review all sustainability-related websites, product communications, and reports together with legal teams to identify and revise non-compliant environmental claims. 

• Establish clear internal guidelines, including concrete examples of compliant wording and defined approval processes for sustainability-related statements. 

• Conduct a peer analysis of key competitors’ sustainability communications to identify areas of genuine strength and develop credible differentiation messages. 

• [For large communications teams:] provide targeted training for communications and sales functions, using practical examples of sustainability messaging that is both compliant and effective.