New regulations for environmental advertising on products and packaging will come into effect in Germany on 27 September 2026. The Markenverband (Brand Association) and a broad alliance of associations are warning of possible consequences for goods already produced and are calling for a clear sell-off period.
The new requirements of the EmpCo directive concern statements such as „climate-friendly“ or „environmentally friendly“ as well as certain sustainability labels on products and packaging. These may only be used under stricter conditions in the future. According to the associations' assessment, this means a considerable organisational and economic effort for companies, as numerous packaging items will need to be checked and revised.
Focus on already produced goods
One central problem highlighted by the alliance of associations concerns products that were legally manufactured or placed on the market before the cut-off date but are still in storage or on the shelves on 27 September 2026. Particularly with consumer goods and foodstuffs that have a longer shelf life, packaging is often planned, produced, and stored long in advance.
Without a clear transition and sell-off period, faultless products with previously permitted environmental advertising might no longer be sold. In the worst-case scenario, according to the alliance of associations, goods and packaging would have to be destroyed. This could cause economic damage amounting to millions and, at the same time, contradict the sustainability goals of the directive.
Demand to the Federal Government and the EU Commission
The Markenverband points out that both the Bundestag and the Bundesrat have already addressed the problem. The Bundestag has called on the Federal Government to advocate for an appropriate sell-off period at the European level. The Bundesrat has also spoken out in favour of a corresponding solution.
The association alliance is therefore calling on the federal government to lobby the European Commission for an adjustment to the EmpCo directive. Products that were legally manufactured and put on the market before the cut-off date must continue to be allowed to be sold. The aim is to combine consumer protection, the avoidance of greenwashing and economic common sense.
Source: Brand association
