On September 27, 2026, Germany is set to enforce new regulations concerning sustainability labels and certification schemes. These new rules will mandate that companies employing environmental, social, or employer-related seals ensure their compliance with the updated European Union standards. This initiative is part of Germany’s Third Act Amending the Act Against Unfair Competition (UWG), aligning with the EU EmpCo Directive (2024/825). The reform aims to tighten the criteria for sustainability labels and employer seals used in marketing and recruitment.
The updated framework imposes restrictions on labels not grounded in recognized certification systems or those not established by public authorities. These rules extend beyond environmental claims, potentially impacting social criteria such as workplace conditions, employee satisfaction, fairness, and diversity, depending on the seal’s nature. To be deemed valid, a certification scheme must fulfill several criteria, including transparent documentation, publicly accessible criteria, equal access for organizations, and independent third-party verification processes.
These regulations are likely to impact international companies, including those based outside Germany, if they use employer or sustainability seals when engaging with German customers, employees, or applicants. It is advised that companies employing such certifications review their providers, documentation, and verification processes before the regulations come into effect. The updated rules represent a shift from merely assessing whether a claim is misleading to scrutinizing the credibility and independent verification of the certification system behind the claim.
Organizations with transparent certification processes could gain increased trust, while those with unsupported marketing labels might face legal challenges. Industry experts recommend that businesses prepare by reviewing certification criteria, maintaining evidence of evaluation procedures, and ensuring that all supporting documents are accessible. Additionally, companies should seek legal advice for specific compliance queries related to competition law to ensure readiness for the approaching regulatory changes.
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