The new EmpCo rules focus on specific, clear and verifiable information to diminish broad sustainability promises. This affects any claims about products, materials, certifications, durability, repairability and environmental measures. From 27 September, producers and retailers will therefore face stricter rules for environmental claims. This means vigorously checking and, in some cases, changing product labels or packaging. The German Federal Association of E-Commerce and Mail Order Business; German abbr. BEVH) has also voiced concerns about these requirements.
New burden of proof for sustainability
General claims including terms such as “sustainable”, “environmentally friendly”, “climate-friendly” or “green” can be risky if there is no evidence backing them up. A positive environmental feature of one part of a product also cannot automatically be applied to the whole product.
Companies should carefully check:
- Online shops, landing pages and older web content
- Google and Microsoft Ads
- Product feeds and marketplace listings
- Newsletters and social media
- PDFs, white papers and presentations
- Packaging, product materials and sustainability labels
- Press, marketing and sales materials
Images, colours, symbols and company-created sustainability labels can also be seen as environmental claims.
Keep the product, change the packaging?
Existing packaging does not necessarily have to be thrown away. One German chocolate manufacturer, for example, updated packaging that had already been produced by covering a sustainability claim with a sticker. The company replaced it with a different product statement, while keeping the certified cocoa information on the back. This measure made for a quick and easy response to the new requirements without wasting existing packaging.
Every claim needs evidence!
Producers and retailers should review all environmental claims, including older content that is still online. PDFs, landing pages and product data can remain visible to customers and continue to make environmental claims. Every claim should be supported by clear, verifiable evidence. Simply referring customers to a link, QR code or footer is not enough.
Claims such as “climate-neutral” can be particularly sensitive when they are based only on CO₂ offsetting. Future environmental targets should also include measurable goals, a clear action plan and regular independent checks.
No advertising based on mere compliance
Companies should also be careful with their own sustainability labels, CO₂ offsetting claims and environmental targets without clear action plans. PPWR compliance should not be promoted as a special environmental benefit either. Meeting legal requirements is a basic obligation, not a competitive advantage.
Now is the time to review your sustainability claims and update them where needed.
Need help navigating the new EmpCo rules? trade-e-bility helps companies review their environmental claims, identify risks and build compliant product communication. Get in touch for your tailored solution!

