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Three things sustainability communication can no longer do without

At a glance

  • Environmental claims: since 27 September 2026, the rules of EU Directive 2024/825 (EmpCo) have been part of the UWG, the German Act against Unfair Competition. Generic environmental claims without evidence, labels without a certification scheme and »climate-neutral« based on offsetting are prohibited towards consumers. The planned Green Claims Directive, on the other hand, has not been adopted.
  • DIN SPEC 91484 describes how building products are recorded before deconstruction so that they can be reused.
  • The new Construction Products Regulation (EU) 2024/3110 has applied since 8 January 2026. Under it, manufacturers will gradually also have to declare the environmental performance of their products, starting with global warming potential. An EPD to EN 15804 is the best data basis for this.
  • If you check and back up your environmental claims now, you communicate more credibly than competitors who only catch up later.
Published
07/09/23
Updated
10/10/26
Reading time
8 minutes
Topic
Sustainability
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Contents
  1. Environmental claims: new rules have applied since 27 September 2026
  2. What is now prohibited
  3. Does this affect my company too?
  4. And the Green Claims Directive?
  5. »Ok ciao«, or is the risk also an opportunity?
  6. From green claims to DIN SPEC
  7. And when does the DIN SPEC become a standard?
  8. The new Construction Products Regulation applies
  9. So is an EPD mandatory for building product manufacturers?
  10. Do I need a lawyer now?
  11. Sources
  12. Frequently asked questions

As of October 2026. We first wrote this article while the EU was still negotiating its rules against greenwashing. Much has since been decided, so we have revised it.

Environmental claims: new rules have applied since 27 September 2026

It can feel as if the EU turns out new regulations, directives and initiatives on a conveyor belt. Rarely do they have such direct consequences for building product manufacturers’ sustainability communication as the rules against greenwashing.

  • The reason: »A study carried out by the European Commission in 2020 found that a substantial share of environmental claims (53.3%) across a wide range of product categories in the EU contained vague, misleading or unfounded information about the environmental characteristics of the products. […] The analysis found that 40% of the claims were unsubstantiated.1«
  • The rule: Germany transposed EU Directive 2024/825, EmpCo for short (the EU Directive on Empowering Consumers for the Green Transition), with the »Drittes Gesetz zur Änderung des Gesetzes gegen den unlauteren Wettbewerb« (the Third Act amending the German Act against Unfair Competition). Since 27 September 2026, the new requirements have been part of the UWG.2
  • The aim: environmental claims should be accurate and verifiable. Above all, this takes claims of climate neutrality based on offsetting off the table.

What is now prohibited

Since 27 September 2026, the following, among others, have been unlawful towards consumers:

  • Generic environmental claims without evidence: terms such as »environmentally friendly«, »green« or »climate-friendly« where it is not stated clearly and prominently in the same medium what exactly is meant. They are now only permitted if you can demonstrate recognised excellent environmental performance, for example through the EU Ecolabel or a state-recognised ecolabel such as the Blauer Engel (Blue Angel).
  • Labels without a basis: sustainability labels that are neither based on a certification scheme nor established by public authorities.
  • Claims with the wrong scope: an environmental claim about the whole product or the whole company when it only concerns one aspect, for example only the packaging.
  • Climate-neutral through offsetting: claims that a product has a neutral, reduced or positive impact on the environment because greenhouse gas emissions have been offset.
  • Legal obligations presented as an advantage: presenting requirements that apply to all products in a category as a distinctive feature of your own offer.

Promises for the future, such as »climate-neutral by 2035«, are now only permitted towards consumers with a detailed and realistic implementation plan: with measurable targets and deadlines, regularly checked by independent external experts.2

Does this affect my company too?

Probably, yes. The prohibitions in the annex to the UWG apply to advertising aimed at consumers. But with their website, social media or catalogues, many building product manufacturers also reach consumers. And in business with architects, builders’ merchants and contractors, the UWG also prohibits misleading environmental claims. How strictly the courts see this is shown by the ruling of Germany’s Federal Court of Justice (Bundesgerichtshof) of 27 June 2024 on »klimaneutral« (climate-neutral): anyone advertising with an ambiguous environmental term has to explain what is meant in the advertisement itself. A reference to the website is not enough. The advertisement in question had appeared in a trade newspaper.3 Whether a specific claim falls under the new rules has to be assessed case by case.

And the Green Claims Directive?

The EU also wanted a separate directive on environmental claims, the Green Claims Directive. It provided for independent bodies to check environmental claims before they are published. Parliament approved it in March 2024. In June 2025, the Commission announced that it intended to withdraw the proposal, and the negotiations with the Council were called off. As of September 2026, the directive has been neither adopted nor formally withdrawn. It is not law.4

»Ok ciao«, or is the risk also an opportunity?

The new rules are no reason to stay silent about sustainability. If we are honest: as private individuals, don’t we also suspect greenwashing behind many environmental claims, slogans and labels, and feel put off rather than reassured? This is exactly where the opportunity lies for everyone who can back up their claims.

If you properly back up your environmental claims now, your target groups will see you as credible, and you will have a real lead over competitors who only catch up later.

From green claims to DIN SPEC

The construction industry is also under pressure on the circular economy. Architects need to have answers to what happens to building products after deconstruction. That is why Concular and Dominik Campanella (Co-Managing Director of Concular), who initiated it, developed DIN SPEC 91484, a specification published by DIN, the German Institute for Standardisation, together with other players from the construction sector.5

In a nutshell, the DIN SPEC is a procedure for recording building products in order to determine their potential for subsequent use after deconstruction. More precisely, it comprises the following components:

  • Definition of requirements for gathering information, the target document, the process, the players involved and the tools.
  • This information is made available as a guide for preparing »pre-demolition audits« (PDA).
  • For data exchange, the aim is a uniform data format to ensure compatibility with other formats.

In short, the DIN SPEC is meant to help identify building products that are suitable for reuse, so that materials can be returned to the cycle and resources saved.

And when does the DIN SPEC become a standard?

A DIN SPEC is a kind of preliminary stage to a standard and has the advantage that it is produced more quickly. That is exactly what the construction industry needs: speed and procedures that contribute to circularity. DIN SPEC 91484 was published in September 2023 and remains valid in this version; it has not yet become a standard. Since February 2026, DIN SPEC 91525 has built on it: it describes how a concept for the subsequent use of building products from existing buildings is drawn up.7 So Dominik Campanella’s greatest wish still stands: »With the procedure described in the standard, the existing building stock is systematically recorded and documented. This not only gives industry a clear framework for action, but also encourages legislators to link future deconstruction and conversion work to this document.«6

The new Construction Products Regulation applies

The EU Construction Products Regulation is new too. Regulation (EU) 2024/3110 has been in force since 7 January 2025 and has applied since 8 January 2026. It is gradually replacing the old Regulation 305/2011: the new obligations only take effect for each product family once its new harmonised standard becomes binding.8

For sustainability communication, one change matters above all: in the declaration of performance and conformity, manufacturers must also state the environmental performance of their product over its life cycle. The first focus is the impact on climate change, that is, global warming potential. Further environmental indicators will follow from 9 January 2030 and 9 January 2032. A notified body checks the information. The Commission is converting the product families one after another; according to its work plan, the first include precast concrete products, structural steel products and cement. On top of this comes a digital product passport for construction products. When it becomes mandatory depends on a legal act that the Commission has to adopt for it.

So is an EPD mandatory for building product manufacturers?

Not directly: the term EPD does not appear in the regulation. However, the environmental information is calculated using factors based on the same standard as an EPD, EN 15804, and the Commission is to provide software for this. So if you have an up-to-date EPD, you have a good data basis. On top of that come the requirements of the design process: some architects categorically rule out products if there is no EPD or if they cannot be found in Ökobaudat (the German federal database of life cycle data for building materials). And from 1 January 2028, the global warming potential over the life cycle must be calculated for new buildings with more than 1,000 square metres of usable floor area and stated in the energy performance certificate, and from 2030 for all new buildings. This has been set out since July 2026 in the Gebäudemodernisierungsgesetz (GModG, the German Building Modernisation Act), formerly the GEG (Building Energy Act), which transposes the EU Energy Performance of Buildings Directive.9, 10 For this, specialist engineering consultants (building services, structure, fire safety) need reliable product data.

Do I need a lawyer now?

To check individual claims, if in doubt, yes. If your instinct is to run a mile at the mention of environmental claims: you are not alone. Even so, it is worth taking the new rules as an opportunity to focus on the occasions for communication that really matter and to communicate about sustainability in a transparent, relevant and comprehensible way.

You can read how to anchor sustainability communication internally first in our article »Internal first«. Together with Dr. Daniel Kendziur (SKW Schwarz), we explained which claims have been critical since 27 September in the Industry Update »Green claims from September 2026«.

Would you like to check your environmental claims or train your team on them? Write to us.

This article reflects the situation as of October 2026 and does not replace a legal review of individual cases.

Sources

Frequently asked questions about this article

What happens if our website still carries an unsubstantiated environmental claim?

If it falls under the new prohibitions in the annex to the UWG, for example as a generic environmental claim without evidence, it has been unlawful towards consumers since 27 September 2026. Competitors and associations can send formal warning letters (Abmahnungen) and sue for injunctions. For widespread infringements in several EU member states, the UWG provides for fines of up to 4% of annual turnover. In business with architects, builders’ merchants and contractors, misleading environmental claims are also unlawful.

Our products already have an EPD. Is that enough for the new Construction Products Regulation?

An EPD to EN 15804 is the best basis, but it does not replace the information the regulation requires. Legally, what counts is what is stated in the declaration of performance and conformity. When this applies to your products depends on when the new harmonised standard for your product family becomes binding. Check now whether your EPD is up to date and covers the whole life cycle.

How do I make my products compatible with DIN SPEC 91484, and what data do I need to provide?

You need to prepare your product data so that it can feed into a pre-demolition audit. This includes information on material composition, joining techniques, separability and the potential for subsequent use after deconstruction. Provide this data in a uniform format so that it is compatible with existing systems.

Which existing marketing materials should we review first?

Start with everything that contains terms such as »climate-neutral«, »environmentally friendly« or »sustainable« without stating alongside exactly what is meant. Then your own seals and labels, claims that apply to the whole product but only concern part of it, and promises for the future such as »climate-neutral by 2035«. This applies equally to your website, catalogues, data sheets, trade fair stands and social media.

How do I communicate sustainability topics to architects without being suspected of greenwashing?

Rely on concrete figures and verifiable evidence instead of promotional superlatives. Architects increasingly work on the basis of data, and some categorically rule out products without an EPD or reliable environmental data. Provide your evidence where planners look for it in their everyday work: in BIM objects, on tender platforms and in technical data sheets.

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