September is marked by stricter requirements for environmental communication and packaging compliance.
A critical deadline is approaching for companies:
On September 27, 2026, the new rules for sustainability claims (green claims) will officially take effect in Germany.
Stricter Rules for Green Claims
Starting September 27, the new requirements for implementing the EU’s “Empowering Consumers for the Green Transition” Directive (EmpCo) will apply in Germany.
For companies, this means:
- Ban on vague claims: General terms such as “environmentally friendly,” “eco,” or “green” are prohibited without direct, recognized evidence.
- End of pure carbon offset advertising: The claim “climate-neutral” based solely on CO₂ certificates will no longer be permitted.
- Certified seals: Sustainability seals must be based on official or independent, transparent certification systems.
What to do now:
Review your websites, packaging, and marketing materials. As of the effective date, all claims used must be legally sound and fully verifiable.
PPWR: The Implementation Phase Begins After the Launch
The PPWR has been in effect since August 12, 2026, alongside the German VerpackDG. Companies are now in the midst of implementing the new requirements.
In September, the focus will therefore be primarily on practical implementation:
- Direct bans: Packaging that comes into contact with food may no longer exceed certain PFAS limits.
- Declaration of conformity: Manufacturers must demonstrate that all packaging complies with the new sustainability standards.
- Cross-border trade: Anyone shipping to other EU countries must be registered in the destination country starting with the first package and often must appoint a local authorized representative.
What to do now:
Review existing packaging and EPR processes and integrate the new PPWR requirements into the compliance structure.
Textile EPR: Germany Continues to Work on National Implementation
Things remain exciting on the textile EPR front as well. Back in March, the Federal Ministry for the Environment published key points for expanded producer responsibility for textiles. The goal is to have manufacturers contribute more toward the costs of collecting, sorting, reusing, and recycling used textiles.
A concrete draft bill for the new German Textile Act is expected shortly.
What to do now:
Closely monitor the legislative process to factor future EPR fees – set to take effect in 2028 – into your calculations early on.
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