Germany is set to implement new regulations on sustainability labels and certification schemes by September 27, 2026. These upcoming rules will require companies to ensure that their environmental, social, or employer-related seals adhere to updated EU standards. This change is part of Germany’s Third Act Amending the Act Against Unfair Competition (UWG), which incorporates the EU EmpCo Directive (2024/825). The reform aims to impose stricter criteria for sustainability labels and certain employer seals utilized in marketing and recruitment efforts.
The revised framework will place restrictions on labels that do not originate from recognized certification systems or are not established by public authorities. The regulations will cover not only environmental claims but also social factors, including workplace conditions, employee satisfaction, fairness, and diversity, depending on the seal’s nature. To be considered valid, a certification scheme must satisfy several criteria, such as transparent documentation, publicly accessible criteria, equal access for organizations, and independent third-party verification. Companies must ensure their seals are backed by clear methodologies, audits, and reliable evaluation processes.
These regulations could impact international companies, including those outside Germany, if they employ employer or sustainability seals aimed at German customers, employees, or applicants. Businesses using such certifications are advised to review their providers, documentation, and verification processes before the regulation’s implementation. The updated rules emphasize the importance of the credibility and independent verification of the certification system behind a claim, rather than merely assessing whether a claim is misleading. Organizations with transparent certification processes may gain increased trust, while unsupported marketing labels could face legal challenges.
Industry experts suggest that companies prepare by checking certification criteria, maintaining evidence of evaluation procedures, and ensuring all supporting documents are accessible. It is also recommended that businesses seek legal advice for specific compliance questions related to competition law. By doing so, companies can better navigate the new regulations and ensure their marketing and recruitment practices remain compliant.
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