Sustainability is no longer a niche topic – it is a decisive purchase reason for many consumers. But with growing interest, the danger of falling into the greenwashing trap also increases. The European Commission finds that 53% of environmental claims (EU Commission) are vague, misleading or unfounded. From 27 September 2026, tightened rules apply. This article shows you how to communicate authentically and legally as an e-commerce retailer.
What is Greenwashing?
Greenwashing refers to misleading marketing practices in which companies portray themselves or their products as more environmentally friendly than they actually are. The term is composed of "green" (environmentally friendly) and "whitewashing" (cover-up).
The European Commission has systematically examined environmental claims online: 40% of claims (EU Commission) had no supporting evidence. At the same time, consumers are becoming more critical and see through superficial sustainability promises increasingly faster.
Greenwashing can be subject to cease and desist orders under competition law as misleading advertising. From 2026, the EU directive will significantly tighten requirements.
Typical Greenwashing Practices in E-Commerce
In online retail, we encounter certain greenwashing patterns particularly frequently. From 27 September 2026 they fall under the tightened rules of the Unfair Competition Act blacklist – regardless of whether they appear in an advertisement, a product description or a newsletter.
- Vague terms: "eco-friendly", "green", "sustainable" without evidence
- Misleading labels: Self-designed seals without independent verification
- Hidden trade-offs: One aspect sustainable, others problematic
- Irrelevant claims: "CFC-free" for products that did not contain CFCs in the first place
- Lesser of evils: "The most environmentally friendly product in its category"
- Imagery: Green colors and nature motifs without substantive basis
The "Carbon Neutral" Problem
The claim "carbon neutral" is particularly problematic. The term is ambiguous: it can mean that less CO2 arises in the production process itself – or that emissions are offset elsewhere through certificates. The latter is often the case, so the actual emissions remain.
On 27 June 2024 the German Federal Court of Justice ruled (I ZR 98/23) that advertising with an ambiguous environmental term such as "carbon neutral" is regularly permissible only if the advertisement itself explains what the term specifically means. In the court's view, reducing and offsetting CO2 emissions are not equivalent measures.
What Applies from September 2026: EmpCo, Not the Green Claims Directive
What binds is the EmpCo Directive (EU) 2024/825, transposed in Germany through the third act amending the Unfair Competition Act (published 19 February 2026) and applicable from 27 September 2026. The frequently cited Green Claims Directive, by contrast, is a 2023 proposal that the Commission has not been negotiating since June 2025; it has no application date. The EmpCo rules set new standards for environmental claims in advertising and have direct implications for product descriptions and marketing in e-commerce. Beyond advertising claims, supply chains are also coming into focus: the EUDR deforestation regulation requires retailers to provide evidence of deforestation-free products. The practical shop-side changes are covered in the article on environmental claims under EmpCo.
Evidence Requirement
All environmental claims must be supported by independent, scientifically based evidence.
Verification
Labels and seals must be verified and certified by accredited third parties.
Transparency
Consumers must have easy access to detailed information about environmental claims.
Sanctions
Violations are subject to significant fines and legal action by competitors.
Legal Risks for Online Retailers
Greenwashing is not just a reputational risk – it can have concrete legal consequences. Competition law prohibits misleading commercial practices.
| Violation | Possible Consequence | Example |
|---|---|---|
| Misleading advertising | Cease and desist | "100% sustainable" without proof |
| Unfair comparisons | Damages | "More sustainable than competitor X" |
| Widespread infringement (Section 19 UWG) | Fines up to 50,000 euros | Fake environmental seals |
| Greenwashing under the UWG blacklist (from 27.09.2026) | EU-wide sanctions | Unsubstantiated carbon neutrality |
The Kantar Sustainability Sector Index reports that 52% of consumers (Kantar Sustainability Sector Index) believe that companies distribute misleading or false information about their sustainability efforts. If a company is found guilty of greenwashing, the loss of trust can be more severe than any penalty.
Authentic Sustainability Communication
The good news: Genuine sustainability can be communicated effectively and legally. The key lies in transparency, evidence, and realistic statements.
Best Practices for E-Commerce
- Specific numbers instead of vague terms: "30% less CO2" instead of "eco-friendly"
- Independent certifications: GOTS, FSC, Blue Angel, EU Ecolabel
- Transparent supply chains: ERP integration for traceable origin
- Honest communication: Also openly name potential for improvement
- Scientific evidence: Link to studies and test reports
- Lifecycle consideration: Consider the entire product lifecycle
Create a dedicated sustainability page in your online shop where you explain your measures transparently and in detail. Link to it from product pages.
Wording: Dos and Don'ts
| Risky (Greenwashing) | Legally Safe | Reason |
|---|---|---|
| "100% sustainable" | "GOTS-certified organic cotton" | Specific + certified |
| "Carbon neutral" | "CO2 offset (Gold Standard)" | Transparent method |
| "Eco-friendly" | "30% recycled material" | Measurable claim |
| "Green product" | "FSC-certified wood" | Independent verification |
| "Good for the environment" | "Reduces water consumption by 40%" | Concrete saving |
Technical Implementation in Online Shops
Your shop's technical infrastructure can support authentic sustainability communication. With Shopware 6 or WooCommerce, corresponding functions can be integrated.
- Product attributes: Sustainability features as filterable properties
- Certificate badges: Integration of official seals with links
- CO2 calculator: Transparent display of footprint per product
- Supply chain tracking: ERP interfaces for proof of origin
- Sustainability filters: Customers can filter specifically
<!-- Example: Sustainability badge with proof link -->
<div class="sustainability-badge">
<img src="/images/gots-certified.svg" alt="GOTS certified">
<a href="/sustainability/certificates/">View certificate</a>
</div>
<!-- Structured data for Google -->
<script type="application/ld+json">
{
"@type": "Product",
"hasCertification": {
"@type": "Certification",
"name": "GOTS",
"certificationIdentification": "GOTS-12345"
}
}
</script>Consumer Reactions to Greenwashing
The consequences of exposed greenwashing can be devastating. Consumers are increasingly sensitive and share their experiences on social media.
Purchase Boycott
Many consumers permanently avoid brands after greenwashing scandals
Social Media Backlash
Negative experiences spread virally and reach millions
Loss of Trust
Once lost, trust is difficult to regain
Quality seals are a shortcut in the purchase process for many customers: they replace checking for themselves. If this trust is disappointed, they turn away – and share their disappointment online.
Checklist: Avoiding Greenwashing
- All environmental claims are backed by independent sources
- Seals used come from accredited certifiers
- Product descriptions contain specific, measurable information
- A sustainability page transparently explains all measures
- Potential for improvement is openly communicated
- Visual language corresponds to the actual level of sustainability
- Legal review of all environmental claims before publication
- Regular updating of sustainability information
Honesty as Competitive Advantage
Greenwashing is tempting in the short term but risky in the long term. The EmpCo rules from September 2026 significantly tighten requirements, and consumers are becoming increasingly critical. Authentic sustainability, on the other hand, becomes a real competitive advantage.
Invest in genuine sustainability measures and communicate them transparently. With the right e-commerce strategy and technical implementation, sustainability becomes a differentiating feature that builds trust and retains customers.
As an experienced e-commerce agency, we support you in the legally compliant design of your sustainability communication – from strategy to technical implementation in your online shop.
The governing instrument is the EmpCo Directive (EU) 2024/825, transposed in Germany through the third act amending the Unfair Competition Act and applicable from 27 September 2026 - with no transition period for existing advertising. The Green Claims Directive is a separate proposal with no application date.
Under competition law, cease and desist letters from competitors or consumer protection associations with injunctive relief and possibly damages claims are possible. From 27 September 2026 the greenwashing provisions sit on the blacklist of the Unfair Competition Act. For widespread infringements, Section 19 UWG provides for fines up to 50,000 euros, and up to 4% of annual turnover for companies with high revenues.
Reputable seals such as GOTS (textiles), FSC (wood/paper), Blue Angel or EU Ecolabel are awarded by independent, accredited bodies and regularly audited. Self-designed seals should be avoided.
The term is legally problematic. According to German Federal Court rulings, it must be transparently explained how carbon neutrality is achieved (e.g., through offsetting). Recommendation: Use more specific wording like "CO2 offset according to Gold Standard".
With Shopware 6 or WooCommerce, sustainability attributes can be created as filterable product properties, certificate badges can be integrated, and structured data can be added for Google. We are happy to advise you on the optimal implementation.
Environmental claims should typically rest on independent, traceable evidence – such as certificates from accredited bodies, test reports, or life cycle assessment data. It is advisable to phrase each claim specifically and measurably (e.g., "30% recycled material") and to transparently link to the underlying proof. This significantly reduces the risk of cease and desist actions under competition law.
This article draws on: European Commission (Green Claims, environmental claims online), the German Unfair Competition Act (Sections 5, 5c and 19 UWG), the German Federal Court of Justice (judgment of 27 June 2024, I ZR 98/23) and the Kantar Sustainability Sector Index. The figures cited may vary by sample and point in time.