EmpCo Directive 2026: New rules on greenwashing and environmental claims – what changes from 27 September

As of today, stricter rules apply in Germany and Europe to advertising that uses environmental and sustainability claims. Read on to find out what is changing, what it means for companies and consumers and what role the Green Button plays. 

What changes on 27 September 

With the Empowering Consumers Directive (EmpCo Directive), Directive (EU) 2024/825, the European Union has revised the rules on sustainability advertising. The German Bundestag transposed the Directive on 19 December 2025 by amending the Act against Unfair Competition / Unlauteres Wettbewerbsgesetz (UWG). The amending act was promulgated on 19 February 2026 and has applied since 27 September 2026. 

The Directive aims to protect consumers from greenwashing through generic environmental claims and from misleading claims about the environmental and social characteristics of (textile) products. At the same time, it requires companies to communicate transparently by providing specific and verifiable information. 

What this means for companies in the textile and fashion sector 

For companies, this shifts the benchmark. What matters is no longer how a claim sounds, but what evidence supports it and exactly what it refers to. The following points are particularly relevant for traders and retailers in the textile and fashion sector: 

• Generic environmental claims must be specific and verifiable. Vague claims such as ‘sustainable’, ‘environmentally friendly’ or ‘climate neutral’ may no longer be used without further explanation. Anyone making an environmental claim must be able to substantiate it in a comprehensible way. The explanation must be provided directly on the same medium – simply referring to a link or QR code is not sufficient. 

• Sustainability labels need a solid foundation. Certification labels for textiles may now only be used in advertising if they are either based on an independent certification scheme or established by a government agency – the Green Button meets both criteria. Voluntary public or private trust marks or quality marks that highlight the environmental or social characteristics of a product or business activity without being awarded by a government agency or based on an independent certification scheme are no longer permitted. 

• The scope of an environmental claim must be clear. A claim must not give the impression that it applies to an entire product or the entire company if it in fact relates only to part of it. 

• Misleading or false information on durability or reparability is prohibited. Textile products may not be advertised as repairable if spare parts or instructions are not available. Likewise, product characteristics such as ‘free from substance X’ may not be presented as a distinctive feature of a product if they are already required by law. 

• No blanket sell-off and protection periods for goods. There is no blanket sell-off or protection period for goods. However, a transitional provision until September 2028 is envisaged for textile goods placed on the market before 27 September 2026. If legal action is brought over certain infringements of the new EmpCo rules – for example, to stop an advertisement – it is to be assessed on a case-by-case basis whether this is proportionate. Relevant factors include the seriousness of the infringement, the company’s previous efforts to correct it, and the costs and environmental impact of any necessary modification or destruction – of products or packaging, for example. 

What this means for consumers 

Over the years, the market for sustainability claims has become difficult to navigate. Certification labels, self-declared labels and advertising claims sit side by side, with no way of telling who has checked what or what a claim refers to. This is exactly where the new rules come in, protecting consumers from unfair and misleading commercial practices. As a result, consumers receive verifiable and specific information on the sustainability and environmental aspects of (textile) products. In future, anyone who advertises must be able to say what a claim refers to and what evidence supports it. Blanket promises without explanation will disappear from advertising – and what remains will be easier to compare. 

For consumers, little changes with regard to the Green Button itself. One new feature will be visible on some products: where a product does not consist entirely of textile components – because of a zip, for instance – we recommend that licensed companies add the note ‘Applies to textile components’ below the logo. This makes it immediately clear on the product itself what exactly the label refers to. 

The role of the Green Button  

Since 2019, the German Federal Ministry for Economic Cooperation and Development (BMZ) has been the scheme owner of the Green Button. Independent certification bodies accredited by the German National Accreditation Body (DAkkS) check whether companies meet the requirements for corporate due diligence processes – from risk analysis through grievance mechanisms and remedy to reporting. 

According to legal assessment, the Green Button qualifies under the EmpCo/UWG as a sustainability label established by a government agency and is therefore legally privileged. Accordingly, the environmental claims made simply by using the logo on a product are not prohibited generic environmental claims. The claims communicated by the Green Button logo itself are therefore permissible under EmpCo. 

‘As a government-run label, the Green Button welcomes binding rules for substantive environmental and sustainability claims,’ says Christine Moser-Priewich, Head of the Green Button Secretariat. ‘At the same time, I hope that companies will see EmpCo as an opportunity for more credible sustainability communication rather than a reason for greenhushing. It would be a shame if textile companies and retailers stopped talking about their progress in supply chains altogether for fear of cease-and-desist letters. Anyone using the Green Button communicates on a foundation that is government-established and independently verified. Companies remain responsible for their own communication – but that doesn’t mean they have to stay silent.’ 

Any questions? 

The Green Button Secretariat is on hand to support companies with the new requirements. Write to us at info@gruener-knopf.de to arrange a no-obligation meeting. 

The Secretariat is also inviting companies to the Green Button Dialogue Tour 2026, with EmpCo and communication as one of its key topics. Register here for the Green Button Dialogue Tour. 

For more information on using the logo under EmpCo and the German Act against Unfair Competition (UWG), please see the current logo manual.