‘Sustainable’, ‘green’, ‘environmentally friendly’, ‘climate-neutral’ or ‘CO₂-neutral’: These days, such terms are a common feature in many online shops – on product pages, in category descriptions, on banners, in filters or in delivery information. They sound good, reflect the spirit of the times and can positively influence purchasing decisions. From 27 September 2026, however, it is precisely these statements that will pose a risk of receiving a warning letter for shop operators.

Because from then on, stricter rules will apply in Germany Rules on environmental advertising. Not every ‘green’ term is automatically banned – but some phrases can quickly become a problem. This is particularly true if they appear in the shop without a clear classification, explanation or evidence.

In this post, I’ll show you what’s changing, which phrases are becoming problematic, and how you can get your shop ready in good time – before harmless words end up costing you dearly.

Why green claims are now a real issue for retailers

Green marketing terms often appear convincing at first glance in online shops. However, from the legislators’ point of view, this is precisely where the risk lies: customers are quick to associate such terms with a specific environmental benefit – even when the online shop fails to explain exactly what that benefit refers to.

A term such as ‘sustainable’ can refer to the material, the packaging, the production, the shipping, or just a single component. Without clarification, it remains unclear what exactly is being claimed. And sometimes such terms are simply used because they sound good and companies want to give their products a green image, without there being any clearly demonstrable environmental benefit behind them.

It is precisely such vague or unsubstantiated ‘green claims’ that will become a greater problem in future. Environmental claims should clear, comprehensible and verifiable . This is particularly relevant for online shops, because green claims are not confined to sustainability pages. They appear in many different places:

• Product descriptions
• Category texts
• Banners and teasers
• Landing pages
• Filters and product features
• Badges, icons and labels
• Meta titles and meta descriptions
• Checkout instructions and delivery information
• FAQ sections
• Blog posts or advice pages

The real problem is that many shops have no idea where all their green claims are. A term is introduced once, later incorporated into templates, and eventually turns up in dozens or hundreds of places – often in old product descriptions, imported manufacturer descriptions, automated metadata or long-forgotten landing pages from previous campaigns. Mnemonic: You can only resolve Green Claims once you know where they are in your shop. That’s exactly where our free Green Claims Check.

The Green Claims Directive, EmpCo, the Unfair Commercial Practices Act: So what actually applies now?

If you look into this topic, you’ll soon come across a number of terms: the Green Claims Directive, EmpCo, the UWG or greenwashing. In substance, they all sound similar, but they don’t always mean the same thing. For the deadline of 27 September 2026, the most important thing is the EmpCo Policy (“Empowering Consumers for the Green Transition”) is relevant. The aim of this directive is to better protect consumers from misleading environmental and sustainability claims. In Germany, the requirements are being implemented through amendments to the UWG (Unfair Competition Act) implemented.

At first glance, this might seem a little confusing, because not only do we use the term ‘green claims’ in this article, but almost everyone does when discussing this topic: however, the similarly named Green Claims Directive applies to the rules from 27 September 2026 no basis. This is a separate EU project which has been put on hold for the time being. We are therefore focusing our preparations on EmpCo and the new UWG rules. Specific Legal basis is therefore the Directive (EU) 2024/825 of 28 February 2024 on empowering consumers for the green transition.

What changes will there be for your shop from 27 September 2026?

Both the Directive and the UWG are primarily concerned with consumer protection. Accordingly, the new rules affect B2C shops and mixed-model shops in particular – that is, those that advertise to or sell to end consumers. Purely B2B offerings require a separate assessment. At their core, the changes boil down to a simple question: Does the customer really understand what you mean by a ‘green’ claim – and can you explain and substantiate this claim in a way that is easy to understand? Four areas will be particularly relevant:

1. General environmental terms
2. Statements on climate change
3. Sustainability seals, labels and self-created badges
4. Promises for the future

That doesn’t mean that all sustainability claims have to disappear. It does mean, however, that every ‘green’ statement should be scrutinised more closely in future. And yes, some of these claims would then be better off being deleted – whilst others would be better explained or put into context.

1. Broad environmental terms: When ‘green’ isn’t specific enough

Terms such as ‘sustainable’, ‘green’, ‘eco’, ‘environmentally friendly’, ‘climate-friendly’, ‘recyclable’ or ‘biodegradable’ are sensitive terms because they promise a great deal without making it clear what the benefit actually refers to. It is better to make a specific statement, e.g.:

• “Upper made from 80 per cent recycled polyester.”
• “Shipping box made from 100 per cent recycled paper.”

The more precisely you specify what the environmental benefit relates to, the clearer and easier to substantiate the statement becomes.

2. Climate-neutral and CO₂-neutral: Offsetting is becoming a particularly critical issue

Claims such as ‘climate-neutral’, ‘CO₂-neutral’, ‘climate-positive’ or ‘climate-neutral delivery’ become particularly sensitive when they refer to a product, a delivery or a specific service and be based on compensation. This is because, to customers, the term ‘climate-neutral’ often sounds as though the product itself has little or no significant impact on the climate. It is therefore not enough simply to refer to the purchase of carbon credits or external climate protection projects. The safer approach is therefore not to advertise neutrality, but to specify concrete reduction measures. For example:

• “We are reducing packaging material by 30 per cent”
• “Shipping boxes made from 100 per cent recycled paper”
• “Production using electricity from renewable energy sources”

Offset projects can certainly continue to form part of your sustainability strategy – but they should not be used to justify product-related carbon neutrality claims.

3. Sustainability labels, icons and custom-made badges

From our work with various online shops, we know that custom badges, icons or labels are frequently used to highlight sustainable products – for example, ‘Eco Choice’, ‘Green Product’, a green leaf or a self-designed sustainability logo. Such elements can quickly come across as an independent quality mark. The problem arises when this impression is created even though there is no recognised certification system, no independent testing and no transparent criteria behind them. You should therefore check not only the text, but also graphic elements, filters, product tiles and the shop’s own labels.

Proprietary sustainability labels and made-up labels are particularly risky. If a badge appears to be a sustainability label, it must, in future, be based on a suitable certification scheme or have been established by a government body. A mere statement of a company’s own criteria is not sufficient for this purpose. This is to be distinguished from purely factual statements such as ‘packaging made from 100 per cent recycled paper’. Such statements must also be accurate, clearly attributable and verifiable, but do not necessarily appear to be an independent quality mark.

4. Promises for the future: ‘Climate-neutral by 2030’ is not enough – it’s just a nice-sounding phrase

Statements such as ‘climate-neutral by 2030’ will require more than just an internal declaration of intent in future. What is needed is a detailed and realistic Implementation plan with clear, objective, publicly available and verifiable commitments. These include measurable and time-bound targets, the necessary resources, and regular review by an independent external expert. The results of this review must be made available to consumers.

Better understanding of typical ‘green’ claims in the shop

Why you shouldn’t just sit back and ignore critical green claims

If a statement is deemed to be misleading or inadmissible, this may lead to warnings – with tight deadlines, costs for warning letters, cease-and-desist declarations or legal action. It becomes particularly troublesome when the same wording appears in numerous places throughout the shop. In such cases, a minor change to the text can quickly turn into a major undertaking. Added to this is a second risk: trust. Anyone who markets their products on the basis of sustainability is not just selling a product, but also a promise. If that promise later proves to be shaky, it damages their reputation.

That is precisely why you shouldn’t simply leave questionable green claims unchallenged. The better approach is to gather supporting evidence at an early stage and then decide which statements can stand, which need more context, and which need to be amended.

What shop owners should be doing right now, specifically

You don’t have to rewrite everything straight away. It makes sense to follow a structured process:

1. Collecting references: Check where terms relating to the environment, climate and sustainability appear in your shop (including badges, filters, metadata, old text, etc.).
2. Assess the context: Clarify what the statement refers to (the entire product, the packaging, production, dispatch, or just one component?).
3. Check supporting documents: Gather reliable evidence, certificates or internal documentation.
4. Clarifying the wording: Replace general terms with precise statements.
5. Check labels and badges: Make sure that your own labels do not look like official seals.
6. Defining responsibilities: Decide who will review new claims before they are published in future.
7. Setting up new processes: Set out how future content (product descriptions, campaigns, landing pages) will be checked for green claims from the outset.

Do you have a Shopware shop? Then you can make things easy for yourself and use our Green Claims Clean-up use. It helps you to review any ‘green claims’ you’ve found in a simple and structured way.

Important: Don’t wait until just before 27 September 2026 to start. The bigger your shop is, the more instances there are likely to be, and the longer it will naturally take to complete the overhaul.

Free Green Claims Check for your shop

So that you don’t have to search through every page manually, we at Two-point a freeGreen Claims Check ... has been developed. Simply enter your shop’s details and the tool scans all accessible pages on your shop for typical high-risk terms relating to the environment, climate and sustainability. You will then receive, completely free of charge, a clear report listing all the terms found and their exact locations on your shop.

Find your references in just a few steps:

1. Enter the shop URL.
2. Have your shop pages searched automatically.
3. Receive a report via email containing the terms found and specific URLs.
4. Prioritise the sources and then assess them from a technical perspective.

The report not only shows you individual terms, but also gives you an overview of how frequently typical green claims were found, on which pages they appear and in which section they are located – for example, in the page title, the meta description, the body text or in product information. This allows you to see straight away where action is needed – and to prioritise your efforts.

Important: The check does not alter any content in your shop, nor does it replace a legal review. However, it highlights the relevant sections – and that is the crucial first step. Visual claims, seals and the overall context must also be checked manually.

Take the free test now 

By the way: If you have a Shopware shop and your report identifies a large number of issues, you can then use our Green Claims Clean-up use.

FAQ: Frequently asked questions about green claims in the online shop

Will terms such as ‘sustainable’ or ‘green’ be banned from 2026?
No, not automatically. They become particularly problematic when they remain very general, are not explained or cannot be substantiated. The more specific the statement, the better.

Is the Green Claims Directive already in force?
For the cut-off date of 27 September 2026, EmpCo – or rather its implementation under the German Unfair Commercial Practices Act (UWG) – is particularly relevant. The Green Claims Directive is a separate EU initiative.

Am I still allowed to advertise using the term ‘climate-neutral’?
Product-related claims such as ‘climate-neutral’ or ‘CO₂-neutral’ come under particular scrutiny when they are based on offsetting. Specific statements about reductions are generally the safer option.

Are custom sustainability badges permitted?
Custom badges containing specific and verifiable information are permitted. However, if they appear to be an official sustainability label, they must be independently certified or have a statutory basis.

Why isn’t it enough to simply examine the sustainability aspect?
Because green claims often appear in many other places (product pages, filters, metadata, banners, old landing pages, etc.). A systematic review of these instances is therefore essential.

What is the first sensible step?
First, identify all the relevant passages in your shop. Once you’ve done that, it will be easier for you to decide which statements to keep, which need more context, and which should be amended.

Does the Green Claims Check replace a legal review?
No. The check shows you potentially relevant results. A definitive assessment always depends on the specific context and the available evidence.

Conclusion: Find it first, then defuse it

Green claims will not disappear from marketing – and therefore from online shops – from September 2026. However, they must become clearer, more specific and more transparent. The most important step is not to delete everything straight away or to find the perfect new wording. The most important step is to know where these statements actually appear in your shop.

That’s exactly where ZweiPunkt’s free Green Claims Check comes in. It shows you where these terms appear – quickly, clearly and with minimal effort. This means you can take action in good time, before harmless words end up costing you dearly.

 Identifying risky green claims