Sustainability communication

Avoid greenwashing

Sustainability communication that delivers on its promises—legally sound, credible, and effective.

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EmpCo Policy — effective as of
September 27, 2026
Violations can result in a fine of up to 4% of annual revenue sanktioniert werden.
The Problem

Good intentions don't always lead to good results

Many companies are eager to communicate their sustainability achievements—but do so imprecisely. Starting in September 2026, new rules will take effect in Germany: The EmpCo Directive prohibits the use of broad terms such as “climate-neutral,” “environmentally friendly,” or “sustainable” without reliable evidence.

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Unsubstantiated environmental claims

“Environmentally friendly,” “natural,” or “climate-neutral” without evidence of recognized environmental excellence—such as through the EU Ecolabel or EN ISO 14024.

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Pure compensation claims

“We are climate-neutral”—without a clear explanation of whether emissions have actually been reduced or merely offset—has been deemed misleading by the Federal Court of Justice (BGH) since June 2024.

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Self-created eco-labels

A sustainability label may only be used if it is based on a certification system that is transparent, open, and monitored by independent third parties.

This applies to all channels: Website content, social media posts, product packaging, press releases, and annual reports.

Regulatory Framework

Three EU regulations to combat greenwashing

IN EFFECT

EmpCo-Richtlinie (EU) 2024/825

The Empowering Consumers Directive is currently the only binding EU instrument against greenwashing. It has been in force since March 2024 and will become mandatory on September 27, 2026 (Federal Law Gazette 2026 I No. 43).

Target GroupB2C Communication
MechanismProhibitions + Expanded Blacklist (11 Offenses)
SanctionsUp to 4% of annual revenue
IN EFFECT

CSRD (EU) 2022/2464

The Corporate Sustainability Reporting Directive obligates large companies to provide standardized sustainability reporting in accordance with ESRS. Primarily aimed at investors—but corporate publications on websites may also fall under consumer protection law.

Target GroupInvestors / Stakeholders
MechanismReports subject to audit under ESRS
Threshold (Omnibus)> €450 million in revenue and > 1,000 employees
On Hold

Green Claims Directive COM(2023) 166

Designed to complement EmpCo, suspended since June 2025. The proposal called for a scientific Ex-ante verification of all environmental claims. Even without this guideline, EmpCo’s strict rules apply.

Target GroupB2C-Claims (planned)
MechanismEx-ante Verification and Lifecycle Analysis
StatusLegislation on hold (due to opposition from the EPP)
My Approach

Review, evaluate, improve

I help companies make their sustainability communications credible, legally sound, and effective—using a combination of strategic consulting and a proprietary digital verification tool.

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Strategic Consultancy

I analyze all external communications for greenwashing risks and develop a strategy that honestly communicates sustainability achievements—without leaving any room for legal challenges.

Audit of all existing environmental claims in written materials, on websites, and in campaign materials
Identification of critical claims and specific greenwashing patterns
Developing legally sound alternative phrasing that is persuasive without being exaggerated
Establishing an evidence system: Which documents, certifications, and data support which claims?
Establishment of an internal approval workflow for sustainability statements
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Digital Verification Tool

In addition to my consulting services, I use an analysis tool I developed myself that systematically assesses sustainability statements for compliance risks.

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Claim Analysis

Check text manually, via URL, or as full text. Each statement receives a risk assessment based on applicable EU regulations.

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Pattern recognition

A library of typical greenwashing patterns automatically identifies problematic phrasing.

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Evidence Management

Documents and certificates are centrally assigned to claims—ensuring that every statement is verifiably documented.

Approval Workflow

From drafting to review to approval: No unverified statement is published.

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Before-and-after comparison

Revised claims are compared with the original version, including the delta score.

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Audit Reports

Export results as a PDF or Word document—for the legal department, clients, or internal documentation.

Who does this apply to?

Sustainability communication involves more departments than you might think

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Companies with a sustainability strategy

Ensure your communications are in order before the September 2026 deadline—before you receive any warnings.

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Marketing & Communication departments

Know which phrases are still acceptable and which need to be revised.

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Agencies

Develop sustainability-related campaigns and content for clients that are legally sound.

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Companies subject to CSRD reporting requirements

Ensure that public communications are consistent with formal reporting.

The time pressure is real

The EmpCo Directive was transposed into German law on February 19, 2026 (Federal Law Gazette 2026 I No. 43). Starting September 27, 2026, violations may be subject to warnings and sanctions. Anyone who has not reviewed and updated their sustainability communications by that date is taking an avoidable risk.

I help turn this risk into an opportunity: Credible sustainability communication builds trust—among customers, investors, and the public.

Interested in a communication audit?

I look forward to hearing from you.

Get in touch now →