As of: October 2026. We have updated this article to reflect the new rules in the UWG, the German Act against Unfair Competition, which have applied since 27 September 2026.
For the especially curious among you, up front: according to the guide, you are in the green zone with these terms, but only if you explain right next to them exactly what is meant and can back it up:
- sustainable forestry
- designed for disassembly or of modular construction
- easy to repair
- resource-saving
- renewable raw materials
You should avoid these:
- sustainable
- climate positive
- circular
We explain why further down.
In a first part on »green claims«, we put the two EU directives on environmental claims into context. The EmpCo Directive (the EU Directive on Empowering Consumers for the Green Transition) has applied in Germany since 27 September 2026, and its rules now form part of the Gesetz gegen den unlauteren Wettbewerb (UWG). This means that, towards consumers, generic environmental claims such as »environmentally friendly« are now only permitted if what is meant is clearly explained on the same medium, or if there is recognised excellent environmental performance, such as the EU Ecolabel. The Green Claims Directive, on the other hand, has not been adopted.
Even so, we keep seeing brands make false sustainability claims, if not by calculation then out of ignorance. Yet misleading environmental claims were already prohibited before. A prominent example is the fruit gum manufacturer Katjes, which advertised its products in a trade newspaper as »climate neutral« without explaining in the advert itself that this climate neutrality was achieved through offsetting. Germany’s Federal Court of Justice (Bundesgerichtshof) prohibited this in June 2024.
For us, a good reason to give those of you in marketing and sales at building product manufacturers and interior brands a few important tips. In this article, we use examples of how specific terms are classified to sum up how you can stay on the fact-based green path in your communication.
The source of our selection is the guide »Sustainable Product Claims 2.0«, developed and published by GS1 Germany. We spoke to Joanna Behrend of the Competence Center Sustainability at GS1 Germany about the basis for the information and recommendations for use in the document of almost 90 pages. And of course we also tell you where you can download the whole guide for free.
Why does the guide exist and how did it come about?
The purpose of the guide is to promote a shared understanding of the terms used in sustainability-related product communication. It was developed together with companies from retail and industry and with input from other specialists. In addition, a study carried out in cooperation with HHL Leipzig Graduate School of Management, first in 2014, shed light on how consumers understood sustainability-related product claims at the time, and a repeat study in 2022 showed how that understanding had developed. This makes it possible to draw conclusions about how awareness and handling of typical sustainability claims have developed. »The first edition on a wide range of sustainability terms was produced back in 2014. In 2021, in a discussion with our expert group on sustainability, we realised that a lot had happened in the meantime,« says Joanna Behrend. As a result, GS1 Germany put its earlier recommendations to the test and adapted them for the new edition of the guide (2.0).
»Even then, we had assigned various terms to different clusters. But we have now realised that in some cases we were still a little too unspecific. For the new guide, we therefore completed the categories once more; for example, there is now also a category for social terms,« Behrend explains. In general, she adds, understanding of the various terms in sustainability communication has grown, but so has scepticism among end consumers. »Conversely, this means they don’t necessarily have a positive effect on purchasing relevance.«
Our top 7 environmental product claims
Handy for you: the guide tells you which terms you should use and which you had better not. Before our selection, a bitter pill: you’d do better to forget the word »sustainable« as a sales argument in your communication. »The term ›sustainable‹ as such is very unspecific. Even if you form word pairs such as ›ecologically sustainable‹ or ›socially sustainable‹, this is still very vague. That is why it is always advisable to use terms that are as specific as possible. That way, consumers are misled less. To do so, however, you should look at the product as a whole and take the most relevant impact factors into account,« explains Joanna Behrend.
The guide is divided into nine topic clusters: sustainability in general, climate, biodiversity, recycling & recovery, materials & packaging, ingredients, water, animal welfare and social aspects. Some of the 55 terms assigned to them were assessed in a study for comprehensibility, credibility and relevance to purchasing. For all of them, the guide gives a clear recommendation for use, with reasons that are easy to follow.
If you use these terms in your communication, you are right according to the guide or, taking certain restrictions into account, at least »conditionally« right:
- sustainable forestry (biodiversity): »conditionally« recommended. »This term is conditionally suitable for product communication and should only be used together with evidence. In communication, it is advisable to name the relevant raw materials from more sustainable forestry (this includes social and environmental aspects!) using certifications/labels (e.g. certificates such as FSC).«
- designed for disassembly/modular construction (recycling & recovery): recommended. »This term is suitable as a product claim. Where needed, product claims or supplementary information should include additional notes on correct recycling for each component; see also recyclable/suitable for recycling. In addition, the free packaging logo of the dual systems for sorting instructions can help consumers separate and dispose of waste correctly.« Since September 2026, the following also applies: state specifically which parts can be separated, and how.
- easy to repair (recycling & recovery): »conditionally« recommended. »This term is conditionally suitable for product communication and requires supplementary explanation. Product claims should name the product areas/components that are designed to be easy to repair or are available as spare parts, if appropriate together with information on availability in terms of time and place.«
- reusable (materials & packaging): »conditionally« recommended. »This term is conditionally suitable for product communication and requires supplementary explanation. The product claim should explicitly identify a reusable part of the product (e.g. the packaging or the casing) and, where relevant, point out the conditions for reuse (e.g. cleaning, inspection, maintenance…). Caution: it should be ensured that a specific offer for reuse exists: refill station, refill pouch, tab, etc.«
- resource-saving (materials & packaging): »conditionally« recommended. »This term is conditionally suitable for product communication and requires supplementary explanation. Product claims should name the resources together with the actions taken to reduce them or use them more efficiently; where possible, savings should be quantified and evidence for them published or kept available.«
- renewable raw materials (materials & packaging): »conditionally« recommended. »This term is conditionally suitable for product communication and requires supplementary explanation. The sustainability effect of renewable raw materials depends on how agriculture and forestry are managed. This should be described or backed up by a certificate.«
- fair trade (social aspects): »conditionally« recommended. »This term is conditionally suitable for product communication and should only be used together with evidence. Claims about fair trade are usually made at company level. For individual products/raw materials (e.g. cocoa or coffee), however, it is possible to make this clear by using an appropriate label. The standard used or the actions taken in working with disadvantaged suppliers/producers should also be named. References to your own cultivation projects must be transparent and verifiable.«
We can see that most claims work best when they include specific additional information. Some terms such as »climate positive«, »circular« or »zero-waste product«, on the other hand, should be off limits for product communication, however surprising that may seem. Of course, 55 terms are far from covering every aspect. But they contribute to a basic understanding. »Our aim was to make a shared understanding of the terms possible across very different companies. Only if that is ensured can a degree of comparability ultimately be created for consumers,« Joanna Behrend stresses in conclusion.
Want to know all the details now? The document »Sustainable Product Claims 2.0: Ein Leitfaden für die transparente Kommunikation von Nachhaltigkeits-Claims« (a guide to the transparent communication of sustainability claims) by GS1 Germany is free to download here. In addition, GS1 Germany published the application recommendation »EmpCo in Practice« in 2026. It applies the new rules to product claims.
Do you need support in building sound, sustainability-related sales and marketing communication? Then talk to us.
In the Industry Update »Green claims from September 2026«, we discussed with Dr Daniel Kendziur (SKW Schwarz) what has applied under the UWG since 27 September 2026 and which claims are particularly critical.
This article reflects the position as of October 2026 and does not replace a legal review of individual cases.
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About GS1 Germany
In 1974, a barcode was scanned in a supermarket for the first time. This was the beginning of automated checkout and the starting point for GS1 becoming widely known. The machine-readable GS1 barcode with its GTIN is now the universal standard in global trade and is scanned on products ten billion times a day. GS1 standards are the global language for smooth and secure business processes, valid across company boundaries and continents. Today, two million companies from 25 industries worldwide use this language to identify products, locations and assets uniquely, to capture relevant data and to share it with business partners in their value networks.
About Joanna Behrend
Joanna Behrend is Sustainability Manager at the Competence Center Sustainability of GS1 Germany, where she works at the interface between industry and retail companies. She mainly drives topics and projects around product-related sustainability communication and the circular economy, with an emphasis on the digital product passport.
