Green leaf, big impact: What green claims have to do with your design

A green leaf next to the product photo, „sustainably packaged“ in the footer, „climate-neutral shipping“ at checkout: messages like these seem harmless and sell well. Since September 27, 2026, however, they can trigger a cease-and-desist letter. That is because the EmpCo Directive has introduced new, strict rules in Germany for environmental claims – so-called Green Claims.

This by no means affects only eco brands. If you run an Etsy shop, sell photo prints, design packaging, or write product copy as an agency, you can be affected just as much. We show what applies now, which wording and design elements are risky, and how to check your content quickly.

At a glance: What applies now to Green Claims

• Binding since 09/27/2026: The EU Directive (EU) 2024/825, EmpCo for short, has been implemented in Germany through an amendment to competition law (UWG).
• No grace period: The rules also apply to product descriptions, labels, and texts that have been online for a long time.
• Blanket eco terms are taboo: „Environmentally friendly“, „green“, or „eco“ are no longer allowed without proven excellent environmental performance.
• „Climate-neutral“ via offset payments is over: If you achieve a product's neutrality only through CO₂ compensation, you may no longer advertise it as such.
• Your own eco labels are risky: Only labels with a certification scheme and independent verification – or governmental labels – are allowed.
• Images count too: Green leaves, globes, or nature motifs can be assessed like a fully worded environmental claim.
• Everyone who sells to consumers is affected – regardless of industry and size, including from abroad.

What are Green Claims – and why do they affect you too?

Green Claims are voluntary environmental promises in advertising: „recycled“, „climate-neutral“, „plastic-free“, „sustainably produced“. They appear in product texts, on packaging, in social media posts, or on the About Us page. The EU investigated how reliable such claims are – with sobering results: around 53 percent of the claims examined were vague, misleading, or unsubstantiated, and around 40 percent had no evidence at all. In addition, there are around 230 sustainability labels in the EU alone, about half of which are hardly verified or not verified at all.

The new rules therefore do not affect only large brands with sustainability campaigns. They apply to every company that sells something to consumers. A few typical cases from the creative sector:

• Handmade and Etsy: The soap is „100% natural and environmentally friendly“, the candle „sustainable“, the package „shipped climate-neutrally“.
• Photographers and artists: Prints are offered as „ecologically printed“ or on „sustainable paper“.
• Designers and agencies: You design packaging with a leaf icon or write „green“ product descriptions for clients. The client is the one who has to advertise – but when in doubt, the trouble lands on you too, for example when material has to be produced anew.
• Online shops of every kind: A banner saying „climate-neutral shipping“ at checkout or a self-made „Eco-Choice“ badge is enough.
• Retailers with manufacturer texts: If you adopt product images and advertising texts from the manufacturer, you also take on responsibility for the environmental claims in them.

Practical tip: Search your shop or portfolio once for the words „sustainable“, „environment“, „eco“, „green“, „climate“, „CO₂“ and „organic“. Most people are surprised how many hits turn up.

What has applied since September 27, 2026

The EmpCo Directive („Empowering Consumers for the Green Transition“) was adopted in 2024. Germany implemented it with an amendment to the Act against Unfair Competition, promulgated on February 19, 2026. Since September 27, 2026, the rules have been binding. The most important points:

1. General environmental claims such as „environmentally friendly“, „ecological“, or „green“ are only permitted if you can demonstrate recognized excellent environmental performance. In everyday practice, this means: be specific instead of giving blanket praise.
2. Climate neutrality through offsetting: Claims that a product is climate-neutral or has a reduced CO₂ footprint are impermissible if they are based on offsetting emissions – for example via forest protection projects.
3. Sustainability labels may only be used if they are governmental or based on a certification scheme with independent verification. The self-designed „Green Choice“ badge fails.
4. Promises for the future such as „climate-neutral by 2030“ require a concrete, publicly accessible implementation plan with measurable targets and independent monitoring.
5. Part instead of whole: Anyone who makes an environmental claim about the entire product even though it only applies to a part – such as the packaging – is misleading.

Important: There is no transition period in Germany for content that was already online before the cut-off date. The old product text from 2022 is measured just like the new campaign.

And what about the much-discussed Green Claims Directive? It was supposed to additionally bring pre-verification of environmental advertising by independent bodies. The project has been on hold since mid-2025. For you, only the EmpCo Directive currently counts – and it is entirely enough to make advertising open to attack.

What is allowed, what isn't? Practical examples

Not every environmental claim is prohibited. The rule of thumb: the more concrete and verifiable, the safer.

Practical tip: Replace the adjective with the fact behind it. „Sustainably packaged“ becomes „Shipping box made of 100% waste paper, without plastic filler material“. That is more honest, more concrete – and often even more convincing to environmentally conscious customers.

The invisible Green Claims: colors, icons, and imagery

For everyone who designs, this point is the most important: An environmental claim does not have to be written out. A design can also give customers the impression that a product is particularly environmentally friendly – and is then scrutinized just as strictly as a text.

Typical candidates are:

• Leaf, tree, or globe icons next to products or at checkout
• dominant shades of green combined with nature photos, when the product has no concrete environmental benefit
• self-designed badges in a label look („Eco“, „Green Choice“, „Planet friendly“)
• Recycling arrows or symbols that look like official marking
• Stock photos of forest, meadow, or sea on product pages for everyday products

Whether a design counts as an environmental claim in an individual case depends on the overall impression. What is clear, however: a green leaf is no longer a neutral decorative element when it sits next to a product.

Practical tip for designers and agencies: In the briefing, actively ask whether there is evidence for every environmental message – and document the answer. This protects you and your client from expensive correction rounds after printing.

What threatens in case of violations – and your 5-minute check

Misleading environmental claims are a competition violation. Competitors, consumer protection organizations, and qualified associations such as the Wettbewerbszentrale (Center for Protection against Unfair Competition) can issue cease-and-desist letters. Then you face warning costs, in case of repetition contractual penalties from a cease-and-desist declaration, and in a dispute court and attorney costs. For serious, cross-border violations, the EU legal framework also provides for fines of up to 4 percent of annual turnover. On top of that comes a risk that cannot be expressed in euros: anyone caught greenwashing loses trust.

Here is how to get a first overview:

1. Collect all places: Product texts, category pages, About Us and sustainability pages, banners, pop-ups, checkout, shipping emails, social media profiles, marketplace listings.
2. Mark blanket terms: „sustainable“, „environmentally friendly“, „eco“, „green“, „climate-neutral“, „natural“.
3. Check evidence: Is there current, concrete proof for every claim? „According to the manufacturer“ is not enough.
4. Check labels: Is there a certification scheme with independent verification behind every label?
5. Look at the design: Where do icons, colors, or images create an environmental impression that you cannot substantiate?

Unsure? Have your environmental claims checked

The self-check shows where things go wrong. Whether a specific wording, label, or icon holds up legally, however, is often a matter of the individual case. For this, the Händlerbund offers the Green Claims Check:

Book the Green Claims Check now →

Conclusion: Honestly green instead of blanket green

The new rules do not prohibit advertising with environmental benefits. They only require that you say what exactly is environmentally friendly – and that you can prove it. This affects Etsy shops and agencies just as much as large brands, because a single word or icon can be enough. Anyone who does a thorough clean-up now is on the safe side and even gains credibility with environmentally conscious customers.

Frequently asked questions about Green Claims

Does this also apply to small shops and the self-employed? Yes. The rules apply to all companies that sell to consumers – regardless of size and industry. Shops based abroad are also affected if they sell to customers in Germany.

Do I have to revise old product texts? Yes. There is no transition period for existing content in Germany. Since 09/27/2026, what counts is what is currently online.

May I still advertise with „climate-neutral“? Not if the product's climate neutrality is based on CO₂ offsetting. You can, however, state concrete, substantiated savings – such as „30% less CO₂ than in 2023“.

Which labels are still allowed? Governmental labels and those based on a certification scheme with independent verification, for example the EU Ecolabel, the Blue Angel, or FSC. Self-invented labels without an external verification system are impermissible.

Can images and colors also be a Green Claim? Yes. Leaf icons, globes, nature images, or a conspicuously green design can come across like an environmental claim and are then subject to the same requirements.

I only adopt the manufacturer's texts – am I still responsible? Yes. Anyone who adopts advertising material and sells with it is themselves responsible for the claims in it. Therefore, check manufacturer texts just as critically as your own.

What about the Green Claims Directive? The planned EU directive has been on hold since mid-2025. The EmpCo Directive is currently what is decisive.

Sources and further links

• Händlerbund guide: Green Claims – What online retailers need to know
• Händlerbund guide: EmpCo Directive
• Händlerbund: Green Claims Check
• EU Commission: Green Claims
• Directive (EU) 2024/825 (EmpCo) in the Official Journal of the EU

About the Händlerbund: With over 100,000 supported web presences, the Händlerbund is one of the largest online trade associations in Europe. It supports online retailers and creatives with legal texts, legal advice, and checks such as the Green Claims Check.