Environmental Claims

What has changed

Directive (EU) 2024/825 on empowering consumers for the green transition has applied since 27 September 2026, in Germany through an amendment to the UWG (Act Against Unfair Competition). Among other things, generic environmental claims are not permitted if no recognised excellent environmental performance relevant to the claim can be demonstrated.

Which wording is permissible for a specific product is for the legal department to clarify. This entry is not a legal assessment.

Why this matters for your decision

Many companies have to revise packaging, offer pages and campaigns. Afterwards, several permissible wordings often remain: more specific, more verifiable, sometimes more sober. Which of them triggers purchase intent is a marketing question that can be answered in advance.

On top of this comes the well-known gap between attitude and action: in surveys, considerably more people state that they want to buy sustainable products than actually do so at the moment of the offer. The rating of an environmental claim in a survey is therefore an uncertain measure of its effect.

How the effect can be measured

Which environmental claim is permissible is for the legal department to clarify. Which permissible wording triggers purchase intent can be measured in behaviour in advance. In the Painted Door Test, the offer pages differ only in the claim, while product and price stay the same. Real people see one variant and decide whether to click the buy button. Nothing is sold; anyone who chooses the offer is then told transparently that it is a test.

Example

A manufacturer of cleaning products is replacing its previous claim "environmentally friendly". The legal department approves three wordings: "Bottle made from 100% recycled plastic", "Refill pouch saves 70% plastic" and a claim about cleaning performance with no environmental reference.

In the behavioural test, the refill pouch message triggers the highest purchase intent at 3.0%, the recycling claim is at 2.5% and the performance claim at 2.7%. For the packaging, the team chooses the refill claim and keeps the performance claim for the ads.

How it differs

Environmental claims are a form of claim; a claim test checks product claims in general. An eco-label is a marking by a third party, an environmental claim a statement by the provider. The legal review answers whether a claim may be used; the behavioural test answers how it works. Neither step replaces the other.

Limitations

The behavioural test does not check permissibility or verifiability. It requires that only approved wordings are tested, not least because the offer pages look realistic. It also measures the effect at the moment of decision, not long-term effects on trust in a brand. How strongly environmental claims work also depends on category and price; a result applies to the situation tested.