Green claims, sustainability labels, and software update requirements: New stricter competition law regulations
On February 12, 2026, the German Bundestag passed various amendments to the Unfair Competition Act (UWG). In doing so, the legislature is transposing European Directive (EU) 2024/825 ("EmpCo Directive") into national law. The aim is to better protect consumers and market participants from misleading environmental and sustainability claims. In doing so, the legislature is going far beyond the established requirements of case law (VOELKER reported). This results in new requirements, some of which are subject to fines, particularly in the areas of marketing and advertising statements, sustainability claims, and products with software elements. The amendments will essentially come into force on September 27, 2026. VOELKER provides an overview.