Trennhinweis e.V. Welcomes the Implementation of the EmpCo Directive in Germany: New Rules Against Greenwashing

The German legislature has passed the domestic implementation of the European EmpCo Directive, taking strict action against greenwashing and misleading environmental claims. Trennhinweis e.V. welcomes the new regulation, which comes into effect on September 27, 2026, while also clarifying the exact role of the free labels applied to packaging. Although these symbols were already featured on more than 10 billion products in 2024, they do not legally qualify as sustainability seals, ensuring their continued, uninterrupted use.

The Purpose and German Implementation of the EmpCo Directive

According to the press release issued in Munich on July 14, 2026, the German legislature decided to implement the Empowering Consumers Directive (EU) 2024/825 (EmpCo Directive). The primary goal of the new regulation is to eliminate “greenwashing” in advertising and misleading practices related to environmental claims and sustainability seals. The legislative tightening directly strengthens consumer protection, guarantees fair competition in the market for environmentally friendly and sustainable products, and thereby supports environmental protection itself. The relevant amendments to the Unfair Competition Act will enter into force on September 27, 2026. In its official statement, Trennhinweis e.V. indicated its full support for the new, transparent framework.

The Role and Legal Classification of Trennhinweis Labels

The legal status of the waste separation symbols—or labels—provided free of charge by Trennhinweis e.V. for sales packaging is of paramount importance. The organization clarified that the Trennhinweis symbol is not a “sustainability seal,” and is therefore not affected by the new restrictions.

Based on the legal definition, a sustainability seal is a “voluntary public or private trust mark, quality mark or similar, the aim of which is to highlight or promote a product, process or business activity to consumers on the basis of its ecological or social characteristics (or both).”

In contrast, the Trennhinweis label makes no claims about the “ecological or social characteristics” of the marked product. The general purpose of applying the label is to educate consumers about separate waste collection. Through understandable symbols, the labels contribute to proper waste management and the avoidance of “Fehlwürfe” (incorrectly discarded waste). Proper sorting ensures the high-quality recycling of packaging and its return to the raw material cycle, which reduces resource consumption and CO2 emissions. Although the system ultimately relieves the burden on the environment, the label itself does not require a green claim regarding the specific characteristics of the goods.

Quantitative Data and Systemic Impact

The extent of the system and the volume of labels used are well illustrated by the data: in 2024, more than 10 billion sold products were already equipped with the Trennhinweis label to facilitate correct separate waste collection. This massive volume proves the indispensability of the pictograms in quantitatively and qualitatively optimizing the separate collection of packaging waste.

Corporate Tasks and Legal Responsibility

Although the legislative changes only come into effect on September 27, 2026, companies must react and act now, as modifying product packaging and planning marketing campaigns requires significant lead time. In its statement, Trennhinweis e.V. emphasizes that this communication only reflects their own legal assessment of the new legal situation. Irrespective of this, ensuring that sales packaging bearing the Trennhinweis symbol fully complies with all legal requirements remains solely the legal responsibility of the respective manufacturer.

The Mission of Trennhinweis e.V.

Trennhinweis e.V. advocates for the qualitative and quantitative optimization of the separate collection of packaging waste. The association operates as a joint initiative of the dual systems in Germany, which are nationally responsible for the organization, collection, sorting, and recycling of used sales packaging. Packaging manufacturers and retailers can print the symbols provided by the association on their products free of charge, promoting public education and maximizing recycling efficiency.

REFERENCES AND SOURCES:

• Original Press Release: Trennhinweis e.V. – Pressemitteilung (July 14, 2026)

• Official EU Legislation (EUR-Lex): Empowering Consumers Directive (EU) 2024/825 (EmpCo Directive)