Energy Suppliers 2026: Tariff Advertising under EmpCo

Misleading green electricity advertising as a risk: Anyone advertising “green electricity” while actually “greenwashing” grey electricity via mere certificates of origin risks enforcement under the UWG. This is pursued under civil law by competitors, the Wettbewerbszentrale or associations such as the DUH (cease-and-desist and warning-letter proceedings) — not through fines imposed by the Federal Network Agency (BNetzA).

Electricity tariffs: Advertising “100% green electricity” solely through GoO/HKN is liable to be subject to warning letters under Section 5 UWG and the EmpCo Directive (EU 2024/825). Permitted: “Electricity from 100% renewable sources with concrete plant IDs”. Recommended seals: Grüner Strom Label (GSL), ok-power, TÜV SÜD EE01.

Gas tariffs: “Climate neutral natural gas” through offsetting is a per-se prohibition from 2026 (EmpCo). Permitted: Specify the biogas proportion as a percentage, disclose the methodology. Recognised: Biogasregister Deutschland (dena-certified).

Heat tariffs: “Carbon neutral heat” through carbon offsetting is critical according to EmpCo Annex I No. 4c. Permitted: Heat generation mix with kWh proportions per source.

Electricity mix obligations (§ 42 EnWG): Breakdown of energy sources in %, CO₂ emissions per kWh, radioactive waste per kWh, and for green electricity, the generation plant mix.