Sectores
Avoiding Greenwashing in Online Shops: A Guide for E-Commerce
Product descriptions, category labels, shipping claims and self-issued eco-labels: where the biggest EmpCo risks sit in an online shop and how to make environmental claims more defensible.
Online shops communicate sustainability in many places at once: in product texts, in category names, via filters, labels and at checkout. It is precisely this multitude that makes e-commerce one of the largest fields of application for the EmpCo Directive (EU) 2024/825. In Germany it is transposed by the 3rd UWG Amendment Act (BGBl. 2026 I No. 43) and becomes binding from 27 September 2026. This guide shows where the biggest risks lie and how to make environmental claims in the shop more defensible.
Which product descriptions are particularly risky?
The most common risk point is blanket terms in product texts. Words like "sustainable", "eco", "environmentally friendly" or "green" have strong promotional appeal but say little without evidence. Under the EmpCo Directive, such general environmental claims without traceable proof are considered particularly critical because they create an overall impression that cannot be verified.
More defensible are concrete statements about a clearly named aspect: for example "upper made of 60 percent recycled polyester" instead of "sustainable material". What matters is that the claim relates to a verifiable individual fact and not to an indeterminate overall assessment of the product.
How should category labels and sustainability filters be designed?
Many shops group products into categories such as "Sustainable Fashion" or under a filter "environmentally friendly products". The problem: such a filter suggests an objective selection based on clear criteria. If it is not traceable why a product appears in this category, the impression of a substantiated assessment quickly arises that does not actually exist.
Lower-risk is to disclose the filter criteria – for example "contains at least 50 percent recycled materials" or "with an independently verified label". This turns a vague catch-all category into a verifiable selection. The naming should also be descriptive rather than evaluative.
What applies to "climate-neutral shipping"?
The claim "climate-neutral shipping" is widespread at checkout and at the same time high-risk if it rests solely on offsetting the transport emissions. Offsetting-based neutrality claims are among the cases explicitly addressed by the EmpCo Directive. The background and possible alternatives are covered in detail in the article Advertising "CO₂ Neutral": What Is Banned from September 2026.
Instead of a blanket neutrality claim, shops can make concrete statements: for example about the share of low-emission delivery, about consolidated shipping or about transport emissions actually reduced, with a traceable calculation. Where offsetting is used, it should be presented transparently and clearly separated from your own reduction performance.
Are self-issued eco-labels a problem?
Self-issued sustainability labels – such as a green leaf symbol with the addition "Eco Choice" – appear trustworthy but are particularly critical if they are not based on an independent review. The EmpCo Directive explicitly addresses sustainability labels that do not rest on a recognised certification system or an independent verification as a risk case.
Those who wish to use labels have two lower-risk paths: either rely on recognised, independently verified certifications, or make the basis of a self-issued label fully transparent – that is, explain which criteria are checked, by whom and according to which method. A label without a discernible verification basis should, in case of doubt, be removed.
Which further places should shops review?
Environmental claims hide in many places in e-commerce. An inventory should cover at least:
- homepage and campaign banners with blanket sustainability promises
- product and category texts with indeterminate terms
- filters, badges and icons that suggest an assessment
- shipping and checkout claims
- newsletters, product images and packaging notes
For each claim it is worth asking: does it relate to a concrete, verifiable aspect – or does it create an indeterminate overall impression? In the second case, action is needed.
How do shops approach the change in practice?
A pragmatic approach starts with prioritisation by visibility and risk: first prominent, blanket claims on the homepage, in filters and at checkout, then the product texts. Next, vague terms can be replaced with concrete, verifiable statements and unverified labels removed or replaced. Because of long lead times for packaging and print materials, this area should be tackled early.
Since the national implementation of the EmpCo Directive can vary across EU member states, additional care is sensible for cross-border sales. For particularly pointed claims, an individual legal review is advisable.
Conclusion
Online shops are particularly exposed because of their many communication channels. The biggest risks lie in blanket product and category terms, offsetting-based shipping claims and self-issued labels without a verification basis. Those who replace vague assessments with concrete, verifiable statements and put labels on a traceable basis significantly reduce the risk – and communicate more credibly.