Am I no longer allowed to write “eco-friendly” at all?

Towards consumers, a generic environmental claim such as “eco-friendly” has been prohibited since 27 September 2026 if you cannot demonstrate recognised excellent environmental performance (Annex no. 4a UWG). The situation is different if the specification is given clearly and prominently on the same medium. Then the claim is no longer generic, but it has to be true. Whether your specific wording is caught is something to clarify with your chamber of crafts or a lawyer if in doubt.

Does this also apply to images and the logo?

The definition in Section 2(2) UWG expressly names representations through text, images, graphic elements and symbols as well as brand names and company names. Whether a green leaf on its own is already an environmental claim depends on the context. Combined with a line such as “We think about tomorrow”, it can become one. If an environmental term is part of the company name, that is a question for the chamber or a lawyer.

What about “climate-neutral” if we offset emissions?

Claims that are based on the offsetting of greenhouse gas emissions and state that a product has a neutral, reduced or positive impact on the environment are prohibited towards consumers (Annex no. 4c UWG). The directive makes clear that product here covers goods and services. Under recital 12, you may advertise your investments in environmental initiatives, provided the information is not misleading. In that case, describe the project and not your offer as neutral.

Do we have to rebuild the whole website?

Usually not. Often a place can be fixed with one sentence: delete the term or replace it with a specific statement. It becomes more involved when an environmental term is part of the company name, the logo or the vehicle lettering. There you should have the legal position clarified first and then decide. If a relaunch is due anyway, the review belongs in the assessment of the existing content.

What does the review cost, and how long are we tied in?

Small copy changes are included in our website support, which starts at 49 euros per month. Hosting in Germany comes on top from 15 euros per month. Both are cancellable monthly, with no minimum term. We agree more extensive rewrites with you in advance, and in a relaunch the review of existing content is part of the project. Prices as of September 2026.

Eco claims on trade websites: the rules since 27 September

Q: We only work for businesses. Does this affect us?

Under Section 3(3) UWG, the annex listing the practices that are always prohibited applies towards consumers. Anyone who works exclusively for businesses is not covered by this list, but remains bound by the general prohibition of misleading practices, and a vague environmental claim can be misleading there too. If your website also addresses private customers, you should assume the stricter rule applies.

Somewhere on many trade websites there is a green word. The painting firm works in an “eco-friendly” way, the heating engineer is “climate-friendly”, the joinery is “ecological”, and down in the footer sits a home-made badge reading “Green Business”. It was usually well meant, and nobody ever noticed. Since 27 September 2026 a new rule applies: the Third Act amending the German Act against Unfair Competition (UWG) is in force, and generic environmental claims without recognised excellent environmental performance are now on the list of commercial practices that are always prohibited towards consumers (Annex no. 4a UWG). This article is not a legal opinion but a review guide: you go through your website page by page, find the blanket terms, replace them with statements your business can back up, and note down what you need to clarify with your chamber of crafts or a lawyer if in doubt.

Key takeaways

The amended UWG has applied since 27 September 2026. Generic environmental claims such as “eco-friendly” are prohibited towards consumers if the business cannot demonstrate recognised excellent environmental performance (Annex no. 4a UWG).
An environmental claim is not only text: images, graphic elements, symbols and even company names can count as one (Section 2(2) UWG). The review therefore also covers vehicle photos, badges and the header.
In a 2020 study, the European Commission found that 53 percent of the examined environmental claims in the EU were vague, misleading or unfounded and 40 percent were unsubstantiated (European Commission).
What works instead are specific statements the business can back up: which material, which method, which disposal route, which service area. Specific does not automatically mean permitted, but it can be checked.
What the law already requires for all products in a category must not be presented as a special feature of your own offer (Annex no. 10a UWG). Clarify borderline cases with your chamber of crafts or a lawyer.

What changed on 27 September

The Third Act amending the UWG of 12 February 2026 transposes EU Directive 2024/825, which is intended to give consumers better protection against unfair practices in the green transition. The directive requires member states to apply their transposition from 27 September 2026, and the German amending act entered into force on exactly that day (Article 2 of the act, Federal Law Gazette 2026 I No. 43). Two parts matter most for a trade website: new definitions in Section 2 UWG that set out what counts as an environmental claim in the first place, and new numbers in the annex to the act. This annex lists the commercial practices that are prohibited towards consumers without any further weighing of the circumstances. The central new number reads:

Generic environmental claim that cannot be substantiated: making a generic environmental claim where the trader is unable to demonstrate recognised excellent environmental performance underlying it.

Annex no. 4a UWG as in force from 27 September 2026, Federal Law Gazette 2026 I No. 43 - translation of the German original

Two terms in this sentence carry the whole rule. Under Section 2(2) UWG, a “generic environmental claim” is an environmental claim where the specification of the claim is not provided in clear and prominent terms on the same medium. “Eco-friendly” on its own is generic; a sentence that states clearly and visibly what exactly the environmental performance consists of is, under this provision, no longer a generic claim. “Recognised excellent environmental performance”, on the other hand, is narrowly defined: it means performance in line with the regulation on the EU Ecolabel, with officially recognised environmental labelling schemes under DIN EN ISO 14024 Type I, or with environmental excellence under other Union law. Anyone who calls their entire business “eco-friendly” would therefore have to be able to demonstrate such performance. For the work of a trade business as a whole, that proof is likely to be hard to provide in most cases, and an ecolabel for a single product does not cover a statement about the whole business.

Provision in the UWG	What is prohibited towards consumers	How it can look on a trade website
Annex no. 4a	Generic environmental claim without recognised excellent environmental performance	“We work eco-friendly” as the strapline in the header of the home page
Annex no. 4b	Environmental claim about the entire offer or business that only concerns one aspect	“A business that protects the environment”, based solely on the solar panels on the workshop roof
Annex no. 4c	Neutral, reduced or positive impact claim based on the offsetting of greenhouse gas emissions	“Climate-neutral thanks to offset certificates” on the service page or in the vehicle photo
Annex no. 2a	Sustainability label not based on a certification scheme and not established by public authorities	A home-made “Eco Master Business” badge in the footer
Annex no. 10a	Legal requirement for all products in a category presented as a special feature of the offer	Limit values that every paint of this kind must meet anyway, highlighted as your own advantage
Section 5(3) no. 4	Claim about future environmental performance without a detailed, realistic implementation plan with verifiable commitments	“Soon we will work emission-free” without a published plan

Important for context: the list in the annex applies to commercial practices towards consumers, and there, under Section 3(3) UWG, the practices listed are “always prohibited”. It therefore does not matter whether the claim actually misled anyone in the individual case. Who can enforce a breach is set out in Section 8(3) UWG: among others, competitors, qualified consumer associations and the organisations established under the German Crafts Code. For a business that serves private customers, the website is therefore exactly the place where the new rule takes effect. Anyone who works exclusively for businesses is not covered by this list, but remains bound by the general prohibition of misleading practices in Section 5 UWG.

Not legal advice, but a working list

This article describes how to go through your website for blanket environmental terms and what tends to stand out. Whether a particular wording is permitted depends on the individual case: on the exact wording, on its context on the page and on the evidence your business can provide. That decision is made neither by an agency nor by a blog article. The right contacts are the advisory service of your chamber of crafts or a lawyer specialising in competition law.

Why the trades are affected on the website in particular

For most businesses the website has long been their most important channel of their own: according to Bitkom, 94 percent of trade businesses use a website of their own and 88 percent use online directories (Bitkom study report on digitalisation in the skilled trades, 2025 survey). Unlike an advert that disappears after a week, a sentence on the website stays there for years. Some sites still carry copy from a time when “eco-friendly” was considered a harmless self-description, and nobody has touched it since. These old sentences are exactly what a review now needs to find.

There is a measurable reason why the EU is stepping in here. The European Commission had environmental claims examined: in the 2020 study, 53 percent of the claims examined in the EU were vague, misleading or unfounded, and 40 percent were not substantiated at all (European Commission, 2020 study). These figures relate to environmental claims in general, not specifically to the trades. They do explain, however, why the legislator no longer leaves each individual case to be weighed up, but removes blanket terms without recognised proof from advertising aimed at consumers.

A sentence on the website stays until someone changes it

Vehicle livery gets replaced at some point, a flyer gets reprinted. The sentence on the home page, by contrast, stays there until someone deliberately changes it, even when the rule underneath it has changed. That is why the review starts on the website and not on the letterhead.

The review, page by page

The review needs no tool, just a little quiet and a list. Open every page of your website individually, not only the home page, and read it the way a customer reads it: headings, body text, image captions, buttons, footer. Do not just look for individual words, but also for the impression a page creates. The directive expressly points out that a statement in combination with colours or images can constitute a generic environmental claim (recital 9 of Directive 2024/825). These terms and patterns belong on your search list:

The examples from recital 9 of the directive, such as environmentally friendly, eco-friendly, green, nature’s friend, ecological, environmentally correct, climate friendly, gentle on the environment.
Claims from recital 12 that are typically based on offsetting: climate neutral, certified CO₂ neutral, CO₂ positive, climate compensated, gentle on the climate, with a reduced CO₂ footprint.
Word elements such as eco-, bio-, nature- or green- in service names, headings, menu items and in the company name.
Sustainable, resource-saving, future-proof and similar words that hint at environmental performance without naming it.
Promises about the future such as “soon emission-free” or “on the way to climate neutrality”.
Green leaves, globes, ticks and badges that are not backed by any certification scheme.

Step 1

Search for terms

Open each page individually and mark the words from the list, including in image captions, alt texts and the footer.

A hit is not yet a breach, but a place you look at more closely. The following sections go through the areas of a typical trade website in the order in which visitors usually see them.

Home page and strapline

For many visitors the home page is the first page they see, and it often carries the oldest strapline. Typical places are the large heading in the header (“Your eco-conscious painting firm”), the section about the business (“We think green”) and the strip of strengths where “sustainable” sits between “punctual” and “tidy”. These places are sensitive because they refer to the whole business and there is no specification next to them. Check especially carefully here and replace the label with what customers actually want to know: what you work with and how you work. How the home page as a whole should be structured is shown in the article on structuring a trade business home page.

Service pages

On service pages, environmental terms usually sit closer to a specific piece of work, and that is exactly the opportunity. “Eco-friendly facade renovation” is a label. A facade page that describes the insulation material, the build-up and how the old render is handled no longer needs the label. Also watch the scope: if a single service has an environmental property that can be backed up, it must not turn into a statement about the entire business (Annex no. 4b UWG). If you still list your services on one combined page, the article on service pages instead of one combined page gives you another reason for separate pages: a statement stays where it belongs.

References and project reports

Project reports are more credible than any advertising line, as long as they stay with the project. “Environmentally sound renovation of an old building” as a heading is a blanket statement. “Old building, interior insulation with wood fibre boards, clay plaster, windows removed for refurbishment” describes what was done and leaves the judgement to the reader. Also check the short texts under reference photos and the summaries you have written about a project yourself. How to show projects without naming customers is described in the article on showing past work without client names.

Vehicle, workshop and team photos

Under Section 2(2) UWG, an environmental claim is any message or representation in the context of a commercial practice, expressly including representations through text, images, graphic elements or symbols, and brand names and company names are named as well. For the website this means: the photo of the van with the lettering “We drive green” contains a claim, even if it only appears in the image. The same applies to a team photo in front of a wildflower meadow with the line “Committed to nature” above it, because the directive expressly mentions the combination of a statement with colours or images. Go through your image galleries and read every caption within the image as well. If an environmental term is part of the company name itself, that is a question for the chamber or a lawyer and not a quick change on the website. How to choose photos that show rather than claim is covered on the page photos for trade websites.

Badges, symbols and the footer

The footer is where everything ends up that was added at some point: membership logos, awards, badges. Annex no. 2a UWG prohibits displaying, towards consumers, a sustainability label that is neither based on a certification scheme nor established by public authorities. Under the definition in the act, a certification scheme requires verification by a third party. A home-made leaf with “Green Business” has none. For genuine labels, check whether the certificate is still valid, whether it relates to the business or only to a product, and whether the text next to the label reflects that scope correctly.

Do not forget the invisible places

Environmental terms often sit where nobody looks when reading: in the page description that appears in search results, in the alt texts of images, in downloadable service sheets, in the business profile entry in map search and in the email signature. Add these places to the same list, because they are just as public as the visible text.

What works instead of the label

Deleting a blanket word costs you nothing if you put a statement in its place that the customer can follow. The directive describes the difference itself: where the specification of an environmental claim is provided in clear and prominent terms on the same medium, it does not count as a generic environmental claim (recital 9). For a website, the obvious reading is: on the same page, visibly, and not tucked away in a footnote. The table shows how labels become statements that can be checked.

Blanket	Specific	What goes into the evidence folder
“Eco-friendly paints”	“We paint interior walls with low-solvent emulsion paints; we name the product in the quote.”	Technical data sheet and safety data sheet of the product
“Climate-friendly heating”	“Before every quote for a heat pump, we calculate the heating load of your house room by room.”	Service description, sample heating load calculation
“Building ecologically”	“Green roofs for flat roofs, build-up with root protection, drainage and substrate.”	System description, photos of each layer of the build-up
“Sustainable timber”	“Solid wood with proof of origin from the supplier; the quote states which proof is available.”	Delivery note or certificate of the timber supplier
“Environmentally sound disposal”	“We separate rubble and waste wood on site; the disposal records are attached to the invoice.”	Weighbridge tickets, disposal records
“Short distances, climate-friendly”	“We work within reach of our workshop; the places are listed on the service area page.”	List of the places actually served

Material

What is used, named by product group and property. A technical data sheet proves more than any adjective.

Method

How the work is done: build-up, work steps, protection of the existing fabric. A described method can be checked, an advertising word cannot.

Disposal route

What happens to old material and who takes it. Mention legal obligations as information, not as an advantage.

Service area

Which places are served. That is a verifiable statement customers look for anyway, and it replaces the promise of short distances.

Specific does not automatically mean permitted

A specific statement does not fall under the ban on generic environmental claims, but it has to be true. Specific statements remain subject to the general prohibition of misleading practices in Section 5 UWG, which after the amendment expressly also names environmental or social characteristics of goods or services. So only write down what your business does on every job, and not what it did once on a single showcase project.

Four trades, four typical places

Painters and decorators: low-solvent paints

In the painting trade, the environmental term usually appears next to the materials: “eco-friendly paints”, “ecological wall design”. The version that holds up names the product group and the property the customer notices, such as low-solvent emulsion paints for interiors or mineral paints for certain substrates, and refers to the quote for the specific product. Be careful with limit values: what every paint of this kind on the Union market has to meet anyway is not a special feature of your business. How a painter page can be structured as a whole is shown on the page web design for painters.

Plumbing and heating: the heat pump

In plumbing and heating the temptation is strong, because the product itself is associated with climate protection. “Climate-friendly heating with a heat pump” is nevertheless a generic statement, and whether it is true in the individual case depends on the building, the design and the electricity supply. What holds up is a description of the service: which system types you plan, how the heating load is determined, what is checked on site before the quote and how the handover briefing works. Statements about savings only belong on the page together with the basis of calculation. You will find examples of the structure on the page web design for plumbing and heating.

Roofers: the green roof

A green roof has properties that can be demonstrated, and that is precisely why it pays to name them exactly instead of writing “ecological” above it. Describe the build-up layer by layer, the roof types for which you offer greening, and the maintenance the owner takes on afterwards. If you mention an effect, for example on retaining rainwater, then with the manufacturer’s system description as the source and not as a general promise. More on structuring a roofer page is on the page web design for roofers.

Joiners: where the timber comes from

Many customers see wood as an eco-friendly material in itself, and joineries like to carry that image over into their own copy. Anyone who writes “sustainable timber”, however, has to be able to back it up. What is specific and verifiable is the origin: which types of wood you work with, where they come from and which proof of this the supplier provides. If your supplier holds a certificate from a recognised scheme, name it precisely for the products it covers, and not for the whole workshop. You will find ideas for presenting this on the page web design for joiners.

For each of these statements it is worth keeping a small evidence folder alongside the website. It does not need to be elaborate. One entry per statement is enough, as long as it is clear which sentence on which page is covered by which evidence:

evidence-folder-interior-painting.json

{
  "page": "/services/interior-painting/",
  "statement": "We paint interior walls with low-solvent emulsion paints.",
  "evidence": "Technical data sheet of the product used",
  "filed_under": "Evidence/InteriorPainting",
  "check_again": "whenever the product changes",
  "open_question": "none"
}

A legal obligation is not a special feature

One number in the new annex easily catches trade businesses out, because it concerns well-intended diligence. Number 10a prohibits presenting requirements that apply by law to all products in a category as a special feature of your own offer:

Presenting statutory product requirements as a distinctive feature of an offer: presenting requirements imposed by law on all products within the relevant product category on the Union market as a distinctive feature of the trader’s offer.

Annex no. 10a UWG as in force from 27 September 2026, Federal Law Gazette 2026 I No. 43 - translation of the German original

It is worth looking at the following places from this angle. Whether one of them falls under number 10a in the individual case or under the general prohibition of misleading practices is a legal question; they stand out either way:

Limit values that every product of this kind on the Union market has to meet, presented as your own advantage (“Our paints comply with the statutory limit values”).
Labels that are mandatory for an appliance anyway, presented as a distinction of the business.
Obligations in handling waste and hazardous substances as a service promise in the strip of strengths (“We dispose of waste properly”), as if other businesses did not have this obligation.
Requirements every business has to meet, presented as a feature only your business offers.

This does not mean you have to stay silent about obligations. Customers want to know what happens to the old heating oil tank or the rubble. Write it as information in the process section (“We take the rubble with us and pass it on to a certified waste management company; the record is attached to the invoice”) and not as an advertising promise in the strip with your strengths. The difference lies less in the wording than in the place and in the weight the page gives to the statement.

Reviewing copy as part of upkeep or a relaunch

Many businesses did not write the copy on their website themselves and no longer know exactly where which wording appears. Our support and upkeep for your website includes small copy changes, and that also covers replacing individual blanket environmental terms with specific statements. If you are planning a fresh start anyway, include the review in the relaunch of your trade website, because that is where all existing content is reviewed, sorted and moved. In both cases we mark the places, suggest specific wording and ask for the details only your business knows. You decide which version goes live, and you clarify legal questions with your chamber or a lawyer. We do not replace that.

You do not have to write it yourself. How the work is divided is set out in the answer to the question of whether you have to write the copy yourselves: we write the drafts, you correct the technical content. This division of work suits environmental claims well, because only the business knows which material it uses and which proof is sitting in the office. How website copy is written in general is described in the article on writing your own website copy. Which other weaknesses a review like this often turns up at the same time is shown in the article on common mistakes on trade websites. For the review, bring the following:

A list of the materials and product groups you use regularly, with the data sheets you already have.
The certificates, memberships and labels you hold, each with validity and scope.
The disposal route for the waste your jobs produce.
The places you actually serve.
Every wording you are unsure about yourself. It belongs with the chamber or a lawyer before publication.

Website support starts at 49 euros per month, hosting in Germany comes on top from 15 euros per month, both cancellable monthly, no minimum term, prices as of September 2026. The details are in the answer to the question How long am I tied in?. If you use the review as an occasion to put upkeep on a permanent footing afterwards, the article on maintaining the site after handover lists the tasks that come up regularly after launch.

Sources for this article

This article draws on the Third Act amending the German Act against Unfair Competition of 12 February 2026 (Federal Law Gazette 2026 I No. 43), on Directive (EU) 2024/825 and its recitals 9 and 12, on Sections 3 and 8 UWG in the official version, on the European Commission’s page on green claims and its press release of 22 March 2023 on the 2020 study, and on the Bitkom study report on digitalisation in the skilled trades (2025 survey). It does not replace legal advice. If you would like your website reviewed for blanket environmental claims, get in touch.