EmpCo: reviewing environmental claims in your print shop

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What actually changes on 27 September

Germany has already implemented EmpCo. The Third Act Amending the UWG, dated 12 February 2026, was published in the Federal Law Gazette on 19 February. The new environmental advertising rules discussed here apply from 27 September 2026. This is no longer simply an EU proposal.Evidence: [2]

The new prohibitions concern consumer advertising. Purely B2B sales are not a legal vacuum: section 5 UWG also protects other market participants against misleading conduct.Evidence: [4]

Our recommendation is to identify the role your business plays first. Advertising your own shop, proposing artwork for a customer and producing supplied files without changes are different situations. Record who supplies the wording, who answers questions and who approves the final artwork for each job. This responsibilities map is an organisational suggestion, not a replacement for legal assessment of your responsibilities.

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Three distinctions your artwork needs to communicate

• Generic environmental claims require recognised excellent environmental performance relevant to the claim.
• A benefit of individual components must not be presented as a benefit of the whole product or business.
• Sustainability labels must rely on a qualifying certification scheme or be established by public authorities.

Evidence: [1]

Clear, prominent specification on the same medium can take a statement outside the generic environmental claim category. That does not automatically make it lawful; its substance and presentation still require assessment.Evidence: [1]

The distinction around offsetting matters: product claims of neutral, reduced or positive greenhouse-gas impact based on offsetting are prohibited. Transparent communication about financing climate projects remains possible in principle, but must not imply a corresponding product impact. Other rules against misleading advertising still apply.Evidence: [3]

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Start with a claims inventory, not a website relaunch

Open your main product pages as a new customer would. Read material names, selectors, symbols and small notes beside the price, not just paragraphs. Then add quotation templates, sample collections and frequently reprinted customer products. Our proposed audit should produce one shared list rather than five separate correction requests that later drift apart.

Sort the list by the action needed: first public statements with no traceable basis, then reusable templates, followed by less frequently used materials. Give an unresolved statement an owner and a deadline. An open status is more honest and more useful than a green tick that merely means somebody has looked at the page.

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Keep a small evidence record for each claim

We recommend an evidence record attached directly to the statement. A collection of general supplier brochures is not enough for your internal workflow if nobody can identify which paragraph relates to which item. A simple spreadsheet with linked files can be a starting point. Clear relationships matter more than the software you choose.

• Wording and screenshot: what does the customer actually see, including nearby symbols?
• Scope: which item, material and production variant does the statement concern?
• Basis: which document supports this exact statement, who issued it and which version is it?
• Limits: which coatings, finishes or outsourced services are not included?
• Decision: who performed the technical review and, where needed, the legal assessment?
• Change trigger: when should a supplier, material or artwork change lead to another review?

Connect rejected wording to the record as well. A new colleague can then understand why an earlier slogan should not be reused. A short explanation helps someone covering the role much more than a note saying management changed the copy at some point.

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Worked example: a flyer with several paper options

This scenario is fictional and is not a legally approved template. A printer offers the same flyer on several papers. An environmentally friendly heading currently appears above every variant. However, the team finds material-specific evidence for only one paper option. There is no corresponding assessment for an additional finish.

1. Narrow the statement

   The team removes the broad heading from provisional approval and identifies the particular paper property that can be substantiated. It does not infer an environmental assessment of the complete flyer from that information.

2. Connect variant and wording

   Purchasing and the shop owner assign the evidence to the correct item number. A precise description is prepared for technical and legal review for that option. Other variants do not automatically inherit the same text.

3. Test the customer journey

   Before publication, a second person checks different material combinations, the mobile layout and the quotation PDF. They check that qualifications remain visible and that changing the paper option changes the description correctly.

The practical benefit is a traceable decision for each variant. You do not have to suggest every option is exceptionally environmentally friendly. Instead, you can explain the documented property the customer selects. Unresolved options stay unresolved until the necessary evidence is available.

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Follow the correction all the way to the repeat order

Our technical recommendation is to maintain approved statements centrally wherever possible. Product pages, configurators and quotation templates should receive the same maintained information. Mark superseded text blocks clearly and review repeat orders deliberately. Otherwise, the shop may be corrected while a saved basket or old PDF template still contains the previous wording.

Goods already produced are not automatically exempt from the new advertising rules. The Commission FAQ identifies corrections to existing claims as possible measures. Obtain case-specific legal advice on which adjustment is appropriate for your inventory.Evidence: [3]

• Compare the approved version across the shop, sample PDF and quotation templates.
• Check the meaning of German and English copy rather than translating isolated words.
• On a phone, verify that important qualifications remain visible alongside the claim.
• Ask customers with recurring artwork for the specific clarification you need.
• Document a sample check after publication and schedule the next review.

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Take risk seriously without suggesting automatic fines

The frequently quoted 4% limit is not an automatic fine for every incorrect statement. Section 19 UWG concerns widespread infringements of consumer interests and coordinated enforcement. Its turnover-based framework has additional conditions and relates to turnover in affected EU countries. Removal and injunction claims must also be considered.Evidence: [4]

A useful question for your next meeting is therefore: which statement are we publishing, on what evidence, and who decides when something changes? Turn the answer into a small, repeatable process. Technical support can connect data and approvals; assessing the legality of specific advertising belongs with appropriately qualified advisers.