Green Claims 2026: Environmental Claims in Your Shop

With the start of application on 27 September 2026, new rules govern what an online shop may claim about the environmental properties of its products. The binding instrument is not the much-quoted Green Claims Directive – those negotiations have been on hold since June 2025 – but the EmpCo Directive (EU) 2024/825, transposed in Germany through the amendment to the Unfair Competition Act published on 19 February 2026 (Federal Law Gazette). Approximately 53% of all environmental claims in the EU are vague, misleading, or unsubstantiated according to the EU Commission (EU Commission). For e-commerce businesses, that means product descriptions, category texts, SEO content, and marketing claims should be reviewed systematically – there is no grandfathering for existing texts.

Green Claims Directive or EmpCo – What Actually Applies?

Two separate EU initiatives run under the heading green claims, and only one of them binds shop operators. The Green Claims Directive (GCD) is a Commission proposal from March 2023 that would have introduced ex-ante verification of environmental claims by accredited bodies. On 20 June 2025 the Commission announced its intention to withdraw the proposal; three days later the third trilogue was cancelled (European Parliament). Formally the proposal has not been withdrawn – the Commission work programme for 2026 still lists it as pending – but it is not currently being negotiated. Anyone adapting product texts today is therefore not working to the GCD.

What binds is the EmpCo Directive, formally Directive (EU) 2024/825 on empowering consumers for the green transition. It entered into force on 26 March 2024, had to be transposed into national law by 27 March 2026; its start of application is 27 September 2026. Germany transposed it through the third act amending the Unfair Competition Act, published on 19 February 2026 (Federal Law Gazette). Technically it extends the blacklist of prohibited commercial practices with specific greenwashing provisions – a breach is therefore unfair without any further balancing of interests. The background is a proliferation of labels: 230 sustainability labels and 100 green energy labels exist across the EU with vastly different levels of transparency (EU Commission); half of all green labels are weakly verified or not verified at all.

Which Claims Are Prohibited Under the EmpCo Rules?

The EmpCo rules target generic, unsubstantiated environmental claims. For Shopware shops and other e-commerce platforms, this means: in a Commission-led screening of online claims, 42% were found to be exaggerated, false, or deceptive (European Commission). Under the EmpCo rules, generic terms are permissible only where recognised excellent environmental performance can be demonstrated on the basis of Union law – everything else needs evidence or removal.

Offsetting claims are regulated particularly clearly: product-level claims presenting an item as "climate neutral" when emissions are merely compensated elsewhere become impermissible from the application date. The German Federal Court of Justice anticipated this line: in its judgment of 27 June 2024 (I ZR 98/23) it held advertising with "climate neutral" to be misleading, because the advertisement itself must explain what the term specifically means – clarifying information outside the advertisement, for instance via a QR code, does not suffice. Communicating about environmental investments remains permissible as long as it does not become a product-level neutrality claim.

Detailed Requirements for Sustainability Claims

The EmpCo Directive and the amended Unfair Competition Act set specific requirements for every environmental claim. For online shop operators who manage their product data professionally, this translates into clear action areas:

Impact on Shopware Product Data and SEO Content

For Shopware shop operators, the new provisions have direct implications for several areas of shop management. Product descriptions, category texts, custom fields, and SEO-optimised content must be systematically audited for non-compliant claims.

• Product descriptions: Terms like "sustainable", "eco-friendly", or "green" without source references must be removed or replaced with substantiated claims
• Category texts: Labels such as "Sustainable Products" or "Eco Collection" require justification of the criteria products meet
• Meta titles and descriptions: SEO texts with unsubstantiated environmental claims in SERPs can become legally actionable
• Custom fields and properties: Filter attributes like "Sustainable" or "Organic" must be backed by verified certificates
• Cross-selling texts: Recommendations like "Customers also bought these sustainable products" need substance
• Google Merchant Center feeds: Product attributes with sustainability references must meet the new requirements

Eco-Labels and Certifications Under the EmpCo Rules

The new rules also cover eco-labels and certification schemes. A sustainability label may only be used where it rests on a recognised certification scheme or was established by a public authority. Self-developed seals without independent certification fall outside that – even where the underlying criteria are sound.

For online shops this means: self-created labels such as "Shop Eco Seal" or "Our Sustainability Rating" are not permissible under the EmpCo rules. Businesses using proprietary rating systems should replace them with recognised certificates or mark them as company information without label character. There is no grandfathering for seals already awarded.

• EU Ecolabel – official EU environmental label
• Blue Angel – German environmental label (RAL gGmbH)
• COSMOS NATURAL / COSMOS ORGANIC – natural cosmetics standard
• FSC / PEFC – wood and paper products
• GOTS – Global Organic Textile Standard
• Cradle to Cradle – circular economy certification

Penalties and Enforcement

The EU leaves specific penalties to member states but provides a clear framework. For coordinated actions against widespread infringements, the maximum fine must be at least 4% of annual turnover in the member states concerned (Directive 2005/29/EC). In the Netherlands, the authority can impose fines of up to €900,000 per infringement for misleading environmental claims (ACM). Additional consequences include temporary exclusion from public procurement, confiscation of profits from the violation, and publication of the decision – with corresponding reputational damage.

Because the new provisions sit on the blacklist of prohibited commercial practices, a breach is unfair without any further balancing of interests. Competitors, trade associations, and qualified consumer bodies can act against it. The risk of legal challenges in e-commerce rises noticeably – comparable to experiences following the introduction of GDPR or the accessibility requirements (BFSG).

Step by Step: Green Claims Compliance for Online Shops

Moving to substantiated product communication requires a structured process. Professional consulting can help realistically assess the effort and set priorities.

1. Inventory (content audit): Search all product texts, category pages, blog articles, metadata, and marketing materials for environmental claims and document them
2. Assessment and classification: Classify each identified claim as compliant, adjustable, or to be removed – considering existing certificates and evidence
3. Evidence procurement: Request missing certificates and scientific evidence from manufacturers and suppliers, or commission life cycle assessments
4. Content revision: Replace non-compliant claims with substantiated, specific formulations – referencing certificates, studies, or measurements
5. Technical implementation: Create new fields for sustainability evidence in Shopware, upload certificate PDFs, and set up links to audit reports
6. Verification: Have revised content reviewed by legal department or specialised e-commerce consultants
7. Monitoring: Establish regular review of new product texts and automated screening for prohibited terms

AI-Powered Analysis and Content Optimisation

For shops with hundreds or thousands of products, manually reviewing all texts is hardly economical. AI-powered solutions can significantly accelerate the process: automated detection of problematic formulations – much like AI-powered product search, suggestions for compliant alternatives, and systematic data enrichment of large product catalogues with verified sustainability information.

The European sustainability market in e-commerce is growing steadily. 73% of consumers worldwide say they would definitely or probably change their consumption habits to reduce their impact on the environment (Nielsen). At the same time, 52% of consumers worldwide say they have seen or heard false or misleading information about brands' sustainability actions (Kantar). The new rules address precisely this trust gap – and offers companies with genuine sustainability credentials the opportunity to credibly differentiate themselves.

Connection to the Digital Product Passport

The EmpCo rules do not stand alone: they are part of a comprehensive EU regulatory framework for sustainable products. The Digital Product Passport (DPP), which becomes mandatory for further product categories from 2027, will serve as the central carrier of verified environmental data. Those who prepare their product data in a substantiated way today simultaneously lay the groundwork for the Digital Product Passport. The EUDR deforestation regulation is part of the same regulatory package and affects retailers selling products such as coffee, cocoa, wood or leather.

The topics of greenwashing prevention and sustainable shop design also gain additional relevance through the new legislation. B2B retailers face particular challenges as they frequently adopt manufacturer claims in their product descriptions and are liable for their accuracy.

Sustainable Product Communication as Competitive Advantage

Substantiated environmental communication is more than a regulatory obligation – it offers a strategic opportunity. Companies that proactively transition their sustainability communication to scientifically substantiated claims win the trust of an increasingly critical audience. Companies that can substantiate their claims from the outset have nothing to supply later when regulators, competitors or customers ask. Transparency and credibility become the decisive differentiators.

Those who substantiate their environmental claims not only reduce the risk of fines and legal challenges but position themselves as trustworthy providers in a growing market segment. The investment in compliant product communication pays off through higher customer loyalty, better conversion rates among environmentally conscious buyers, and sustainable brand reputation.