Since 27 September 2026, generic environmental claims such as “eco-friendly”, “green” or “climate-friendly” — in German “umweltfreundlich”, “öko”, “klimafreundlich” — are banned in product listings in Germany unless you can show recognised excellent environmental performance, such as an EU Ecolabel or the Blauer Engel. The ban comes from an EU directive that all member states must apply from that date; in Germany it sits in the UWG blacklist. Here is what is covered, what you can still write and how to rewrite supplier copy.
The rule: the EU directive and the new UWG
The basis is Directive (EU) 2024/825 on empowering consumers for the green transition. It added new environmental practices to the blacklist of the Unfair Commercial Practices Directive. Member States had to transpose it by 27 March 2026 and apply it from 27 September 2026 (Article 4). Not every member state had transposed it in time: Germany (UWG) and Italy (Legislative Decree 30/2026) apply the new rules from that date, but if you sell into other countries, check the national law before relying on the date.
Germany did so with the Third Act amending the Act against Unfair Competition (Drittes Gesetz zur Änderung des UWG) of 12 February 2026, BGBl. 2026 I No 43. It applies, in essence, from 27 September 2026 and has three parts:
- new definitions in § 2(2) UWG — environmental claim, generic environmental claim, recognised excellent environmental performance, sustainability label, certification scheme,
- new points 2a, 4a, 4b and 4c in the annex to § 3(3) UWG (the blacklist),
- a rule for claims about future environmental performance in § 5(3) no. 4 UWG (“climate-neutral by 2030”).
Blacklisted practices are prohibited in every case: nobody has to show that a shopper was actually misled or that the claim changed a purchase. The act gives no transition period for existing offers — whatever is online since the cut-off date has to follow the new rules.
What is banned
- Point 4a: a generic environmental claim without demonstrable recognised excellent environmental performance. The directive’s examples are “environmentally friendly”, “eco-friendly”, “green”, “nature’s friend”, “ecological”, “environmentally correct”, “climate friendly”, “gentle on the environment”, “carbon friendly”, “energy efficient”, “biodegradable” and “biobased” (recital 9).
- Point 4b: an environmental claim about the whole product when it concerns only one part — “made from recycled material” when only the packaging is recycled.
- Point 4c: claiming a product is climate-neutral, CO₂-neutral, CO₂-reduced or climate-positive because emissions are offset with credits.
- Point 2a: a sustainability label that is neither based on a certification scheme nor set up by public authorities — including home-made badges such as “Eco Choice” in the product image.
On top of that, § 5(3) no. 4 UWG: a claim about future environmental performance (“climate-neutral by 2030”) needs clear, public and verifiable commitments and a realistic implementation plan that an independent external expert checks regularly. For a single marketplace offer that is practically never the case.
When a claim is “generic”
A claim is generic when it is not specified clearly and prominently on the same medium — that is, in the same listing (§ 2(2) no. 1 UWG). The directive gives its own example: “climate-friendly packaging” is generic, “100 % of the energy used to produce this packaging comes from renewable sources” is specific.
- “Sustainable” (“nachhaltig”), “responsible” or “conscious” go beyond the environment because they also claim social qualities. Recital 10 of the directive says that not even an ecolabel can support them — leave them out as a product property.
- “Energy efficient” can be allowed when the product reaches the top class of the EU energy label (class A under Regulation (EU) 2017/1369). See the guide on the energy label.
- “Biodegradable” cannot rest on an EU Ecolabel whose criteria do not test biodegradability: the performance has to match the specific claim.
- Green leaves, globes or trees in the image are not by themselves a “generic environmental claim” under the blacklist. Combined with a word like “eco” they can be, and they can still be misleading under § 5 UWG.
What you can still write
Specific, verifiable facts remain allowed, as long as they are true, refer to the right part of the product and you can prove them. For Amazon.de, in German:
| Instead of | Write |
|---|---|
| umweltfreundliche Verpackung | Verpackung aus 100 % Altpapier, ohne Kunststoff |
| nachhaltiges Shirt | Shirt aus 100 % Bio-Baumwolle, GOTS-zertifiziert (Lizenz-Nr. …) |
| klimaneutral | leave it out, or state the measured carbon footprint with its source |
| öko Reiniger | Reiniger mit EU Ecolabel (Lizenz-Nr. …), only with a valid licence |
| aus recyceltem Material | Gehäuse zu 70 % aus recyceltem Kunststoff |
Products with an EN ISO 14024 type I ecolabel — in Germany above all the Blauer Engel — or the EU Ecolabel under Regulation (EC) No 66/2010 may make generic environmental claims as far as the label covers them. Other sustainability labels may only be shown when they rest on a certification scheme with independent monitoring or are set by public authorities, and when this very product is certified. Even then a label such as GOTS for textiles covers its specific statement, not a blanket “eco-friendly”.
Why it matters for marketplace sellers
A blacklist breach is easy to prove: one word in the title or a bullet point is enough. Competitors and qualified associations can send a cease-and-desist letter (Abmahnung) and demand a declaration to cease and desist with a contractual penalty. What that costs and how to respond is in the guide on the Abmahnung.
The most common source is supplier and manufacturer copy written before 27 September 2026, and machine translation from English (“eco-friendly” becomes “umweltfreundlich”). Check existing listings too, not only new ones — including image text, A+ content and variations. Cosmetics have rules of their own, see cosmetics claims.
Check your listing
Paste single phrases into the claims checker, or check the whole listing with the free listing check: it finds generic environmental claims in all six languages, together with CE, TÜV and test-seal wording (see “CE-geprüft” and test claims). Whether a label is valid only your certificate can tell — that check stays with you.