Teaser: "Eco-friendly", "green", "natural", "sustainable", these words are standard vocabulary in almost every marketing team. From 27 September 2026, however, they may become one of the most common grounds for warning letters. Annex No. 4a of the blacklist targets exactly these generic environmental claims. We explain which words are critical, what is still likely permissible, and how to systematically audit your copy.

The Problem: The Word "eco-friendly" on Your Homepage

Imagine: your marketing team has redesigned the homepage. The hero banner reads prominently: "Our products are eco-friendly."

That sounds harmless, but in our reading it is one of the highest-risk claims a company can use from 27 September 2026. Why? Because the word "eco-friendly" is a generic environmental claim, and Annex No. 4a of the blacklist explicitly captures such claims without recognised excellent environmental performance.

What Annex No. 4a Prohibits

The provision reads (simplified): a commercial practice where a generic environmental claim is made, where the trader cannot demonstrate that the claim relates to recognised excellent environmental performance.

Two concepts are central:

Generic environmental claim: Under § 2 (2) No. 1 of the German Act Against Unfair Competition (UWG), this is any environmental claim that is not contained in a sustainability label and where the specification is not provided in a clear and prominent manner on the same medium.

Recognised excellent environmental performance: Under § 2 (2) No. 2 UWG, the performance must be based on one of the following systems:

• EU Ecolabel under Regulation (EC) No. 66/2010 ("EU Flower")
• DIN EN ISO 14024 Type I (e.g. "Blue Angel", "Nordic Swan")
• Top environmental performance under other Union law (e.g. energy class A)

The Trigger Words: When a Claim Is "Generic"

The EmpCo Directive and the UWG amendment explicitly name terms that count as generic environmental claims. In our reading, these words are high-risk from 27.09.2026 if no recognised excellent environmental performance exists:

• "eco-friendly" / "environmentally friendly"
• "ecological"
• "green"
• "ecologically compatible"
• "climate neutral"
• "bio-based"
• "energy efficient"
• "nature positive"
• "climate positive"

Additionally, problematic brand and company names are captured. § 2 (2) No. 5 UWG explicitly includes brand names such as "GreenPure", "EcoLine" or "BioNature", in our interpretation these can equally constitute generic environmental claims if no specification is provided.

What Is Likely Still Permissible

Not every environmental claim falls under Annex No. 4a. In our reading, the following statements should be unobjectionable:

Specified Claims

Where the claim is specified in a clear and prominent manner on the same medium. Examples:

• "95 % post-consumer recycled content, certified to Global Recycle Standard GR-2024-123456"
• "70 % fewer CO₂ emissions than the previous model, determined in life cycle assessment to ISO 14067"

Important: "on the same medium" means, according to the prevailing view, on the same packaging, in the same advertisement, on the same sales interface. A QR code that links to a different website is in our reading not sufficient for Annex No. 4a.

Recognised Labels

Where a product carries a recognised Type I label (EU Ecolabel, Blue Angel), the generic claim should be permissible, provided the label is visible on the same medium.

Brand Names Without Environmental Connotation

A manufacturer or brand logo without green connotation does not fall under No. 4a. "Apple" or "Nike" are not environmental claims.

Three Practical Cases

Case 1: "Eco-friendly" on Packaging

Claim: Detergent bottle with the imprint "eco-friendly" on the front.

Problem: Generic environmental claim without specification on the same medium. The back does state "100 % recyclable bottle", but this is not prominent and refers only to the packaging, not to the contents.

In our reading: Likely a violation of Annex No. 4a, possibly additionally of Annex No. 4b (scope).

Case 2: "Sustainable" as a Slogan

Claim: Fashion label with the slogan "Sustainable. Responsible. Conscious."

Problem: Three generic environmental claims without specification. According to the German government's explanatory memorandum (BT-Drs. 21/1855), "sustainable", "conscious" and "responsible" are particularly problematic because they can also suggest social aspirations.

In our reading: Three potential violations of Annex No. 4a.

Case 3: Brand Name "GreenLine"

Claim: A company sells furniture under the brand name "GreenLine Collection" without specification.

Problem: The brand name contains the trigger word "Green" and is an environmental claim under § 2 (2) No. 5 UWG. As no specification is provided, Annex No. 4a may apply.

In our reading: Particularly tricky for established brands, transitional arrangements are lacking.

Three Questions to Ask of Every Claim

1. Does it contain a trigger word? "Green", "eco", "sustainable", "eco-friendly", "climate neutral", every occurrence needs to be checked.

1. Is the claim specified on the same medium? Packaging → on the same packaging. Website → on the same page. TV spot → in the same spot.

1. Do you have a recognised excellent environmental performance? EU Ecolabel, Blue Angel or energy class A, otherwise the generic claim is risky.

How to Audit Your Website Systematically

Most companies have dozens to hundreds of pages with potentially critical wording. A manual review of every single page is time-consuming and error-prone, critical claims in image alt texts or in OCR-captured infographics are easily overlooked.

This is exactly where one feature of GreenClaims Manager comes in: the Findings section automatically lists all detected greenwashing claims, split into text claims, alt-text claims and OCR claims from images. Each finding is displayed with a risk level and a confidence score, so you see at a glance where the need for action is greatest. This is particularly useful for the trigger-word search under Annex No. 4a, because the crawler searches not only visible text but also alt texts and image content.

FAQ

What is a generic environmental claim?

Under § 2 (2) No. 1 UWG, a generic environmental claim is any environmental claim that is not contained in a sustainability label and where the specification is not provided in a clear and prominent manner on the same medium. Typical examples: "eco-friendly", "green", "sustainable".