Green Claims and Advertising Claims Check

Is your environmental or advertising claim legally sound?

Q: Which claims are particularly sensitive?

Particularly sensitive are generic statements such as sustainable or eco-friendly, climate and CO2-neutrality claims, sustainability labels, health and beauty efficacy promises, test winner and No. 1 claims, and comparisons with competitors or earlier product versions.

At ITMR Rechtsanwälte we review advertising claims for the risk of cease-and-desist letters. Since 27.09.2026 the German Unfair Competition Act (UWG) prohibits generic environmental claims without proven recognised excellent environmental performance, climate-neutrality claims based on carbon offsetting and sustainability labels without a certification scheme. For packaging, since 12.08.2026 the following also applies: Art. 14 PPWR. With this check you can make a preliminary assessment of environmental, climate, health and price claims, labels, superlatives and comparative advertising.

Start the check

UWG & misleading advertising UWG annex since 27.09.2026 PPWR Art. 14 since 12.08.2026 Green Claims monitoring Claim dossier

What the review covers

Advertising claims must be accurate in their specific overall impression: wording, imagery, placement, product reference, qualifications, evidence, target group and medium. Particularly sensitive are generic environmental terms, climate-neutrality and offsetting claims, sustainability labels, health claims, “test winner” or “No. 1” statements and comparative advertising.

Preliminary risk assessment for published or planned claims
Prioritisation by claim type, evidence, risk signals and urgency
Specific review points, documents and the next focus for your enquiry

Visual orientation

Claim dossier: from statement to defensible approval

The graphic shows the typical review gates: a claim is not safe just because individual pieces of evidence exist. What matters is whether the core message, scope, evidence, qualification and approval fit together.

Review logic

Typical course of a claim review

Record the claim

Secure the exact wording, images, labels, landing page, packaging, ad or social media post.

Determine the core message

Check what impression consumers, customers, retailers or platforms actually take away.

Assign evidence

Assign studies, measurements, LCA, carbon footprint, certificates, supplier data and methodology to the claim.

Limit the scope

Make the product, packaging, company, period, country, benchmark and system boundaries visible.

Document the approval

Bring legal, marketing, product, sustainability, sales and platform requirements together in one claim dossier.

Assessment

What this check does

The check does not replace a case-by-case review. It does, however, help to reveal typical points of attack: unclear environmental terms, missing substantiation, offsetting communication, overstretched corporate claims, hidden qualifications, regulated product categories and acute urgency.

Which claims are particularly sensitive?

Particularly sensitive are generic statements such as “sustainable” or “eco-friendly”, climate and carbon-neutrality claims, sustainability labels, health and beauty efficacy promises, “test winner” and “No. 1” claims, and comparisons with competitors or earlier product versions.

What role does the EmpCo Directive play?

Directive (EU) 2024/825 (EmpCo) was transposed by the Third Act amending the UWG of 12.02.2026 and has applied since 27.09.2026. Since then, six categories of practices towards consumers are always prohibited (Nos. 2a, 4a, 4b, 4c, 10a and 23d of the annex to Section 3(3) UWG). They concern environmental claims, sustainability labels, statutory requirements presented as a feature, software updates, repairability and consumables, including generic environmental claims without recognised excellent environmental performance, labels without a certification scheme and climate claims based on offsetting. There is no sell-off period. For goods placed on the market before the cut-off date, Section 15b UWG as adopted by the Bundestag requires a balancing of interests before removal and injunctive relief once it is promulgated; in our view it does not help for online statements and advertising materials. Read the article Environmental claims under the UWG

What applies to environmental claims on packaging?

Since 12.08.2026, Art. 14 of Regulation (EU) 2025/40 (PPWR) only permits environmental claims about packaging characteristics regulated by the Regulation itself, such as recyclable, recycled content or compostable, if the packaging exceeds the minimum requirements and the claim states whether it refers to the packaging unit, a part of it or all packaging placed on the market. The evidence belongs in the technical documentation under Annex VII. In addition, Nos. 4b and 10a of the annex to Section 3(3) UWG have applied since 27.09.2026. Read the article Environmental claims on packaging

What is the status of the Green Claims Directive?

The separate Green Claims Directive cannot safely be relied on as a final legal act. The check treats it as a monitoring topic; the UWG, EmpCo, health claims law and product-specific requirements in particular remain binding.

Interactive check

Assess your green claims and advertising claims risk

Answer the following questions. At the end you will receive a preliminary assessment, typical reasons, review points, documents and a copyable summary for your enquiry.

Step 1 of 5

1. Where will the claim be used?

Select the most important context of use.

Product, packaging or labelThe claim appears directly on the product, label, hangtag, insert, packaging or product page. Shop, landing page or product detail pageThe claim appears in e-commerce, on category, campaign, checkout or sales pages. Ads, social media or influencer campaignThe claim is used in heavily shortened form in ads, posts, stories, videos, creator briefings or affiliate campaigns. Corporate website, ESG report or PRThe claim concerns the company, climate targets, sustainability strategy, supply chain or ESG communication. Marketplace or platform listingAmazon, eBay, Etsy, App Store, Google Shopping, Meta Shop, B2B platform or retailer listing. B2B offer, tender or sales materialClaims in presentations, offers, data sheets, white papers, supplier information or tenders. Still unclear or several channelsThe claim is to be used across channels or in several variants.

3. What evidence is available?

Please select everything that is reliably available.

Scientific or technical dataTests, measurements, lab reports, studies, technical specifications or validated calculations. LCA, carbon footprint or life-cycle dataProduct life-cycle assessment, emissions calculation, scope data, system boundaries and assumptions. Independent certification or testingCertificate, audit, accredited testing body, independent validation or recognised standard. Label rules documentedCriteria, awarding body, review process, scope, term and monitoring are traceable. Comparison method documentedComparison product, period, calculation method, data basis, assumptions and updates are clear. The claim is explained specificallyQualifications, footnotes, QR code, landing page, methodology, scope and conditions are transparent. Legal review or approval processMarketing, legal, compliance, product, sustainability and evidence documents are aligned. Supplier evidenceMaterial evidence, certificates, origin, supply chain data, audit reports or manufacturer information. None or only internal assumptionsThe claim is based more on marketing, estimates, supplier statements or unverified information.

5. Is there specific urgency?

Please select all that apply.

Campaign, launch or packaging print deadline is imminentAds, website, packaging, label, influencer campaign or product launch are to go live shortly. The claim has already been publishedThe claim is running in the shop, on packaging, in ads, on social media, marketplaces or in PR material. Warning letter, deadline or lawyer's letterA competitor, association, consumer organisation, rights holder or customer has already reacted. Authority, platform or marketplace is asking questionsA regulator, the Wettbewerbszentrale, Amazon, Google, Meta, App Store, a retail platform or a certifier is requesting evidence. Press, social media or greenwashing riskJournalists, NGOs, customers, review portals or social media are picking up the claim. Retailer, B2B customer or purchasing is requesting evidenceListing, tender, retailer questionnaire, sustainability data sheet or supplier audit. Claim portfolio, rebranding or ESG communication is being rebuiltBrand relaunch, sustainability campaign, new product line, website relaunch or claim guideline. Preventive reviewNo acute case, but claims should become legally more robust before publication.

Deadlines, risks and measures

Typical reference points for claim compliance

Topic	Status	Typical risk	Measure
UWG and misleading advertising	Continuously relevant	Incorrect, incomplete or unprovable advertising can trigger injunction and warning-letter risks.	Review the claim, overall impression, material information and evidence before publication.
EmpCo Directive (EU) 2024/825, Third UWG Amendment Act	Transposition by 27.03.2026; applicable since 27.09.2026	Six new categories that are always prohibited in the annex to Section 3(3) UWG, including generic environmental claims, labels without a certification scheme and offsetting claims; no sell-off period, for existing stock a balancing of interests under Section 15b UWG once promulgated.	Adjust the claim inventory, label use, online statements and advertising materials immediately; Article on the UWG.
PPWR Art. 14, Regulation (EU) 2025/40	applicable since 12.08.2026	Environmental claims about packaging characteristics only above the minimum requirement, with a statement of reference and evidence in the technical documentation under Annex VII.	Check packaging claims against Art. 14 and the UWG annex before print approval; article on Art. 14 PPWR.
Green Claims Directive	Monitoring; no reliably final legal act	Do not treat any deadline as binding current law, but keep monitoring developments.	Document the monitoring and build a robust dossier logic now.
Health, beauty and product claims	Continuously relevant depending on the product	References to efficacy, health, cosmetics or medicine can trigger additional advertising bans and evidence requirements.	Check the product category, mandatory information, body of studies and the specific wording.
Warning letter or platform enquiry	Immediately, depending on the event	Deadlines, blocks, cease-and-desist declarations, reputational damage and preservation of evidence.	Secure the deadline, take live screenshots, consolidate communication and do not make hasty commitments.

Sensible next steps

Related ITMR checkers and follow-up reviews

These follow-up checks fit particularly well with green claims, advertising, e-commerce, campaigns, evidence dossiers and acute warning-letter or reputational risks.

E-commerce warning letter risk checkReviews shop, price, information, button, withdrawal and advertising risks in the sales environment. Newsletter and email marketing checkHelps with consent, existing-customer marketing, unsubscribe link, tracking and campaign approval. Influencer/creator checkAssesses labelling, briefing, claims, product promises, rights and platform rules. Cease-and-desist emergency modeFor running deadlines, lawyers' letters, injunction demands and immediate measures. Image rights / AI image / asset checkReviews campaign visuals, AI images, stock material, personality rights and chains of rights. Document Dossier BuilderStructures evidence, screenshots, claim files, certificates and approvals for legal review.

Have a claim reviewed before launch, packaging print or a response?

ITMR can review advertising and sustainability claims based on wording, medium, evidence, product reference, target group, platform rules and risk situation. A quick assessment is particularly important when claims are already live, a warning letter has been received or retailers, platforms, authorities or the media are requesting evidence.

Send an enquiry about the Green Claims Check

Note: This checker provides initial orientation and does not replace a legal review of the individual case. Advertising claims must always be assessed on the basis of the specific claim, product, medium, evidence, target audience, overall impression and current legal situation. Further background on environmental and health advertising can be found under Product advertising with health & green claims and in the area of Green IP.