Automotive: Greenwashing Risk 2026
The automotive industry has been one of the most prominent examples of greenwashing since the VW diesel scandal. Under Section 5 UWG and the EmpCo Directive (EU 2024/825), even synthetic fuels (e-fuels) and hybrid drives do not justify blanket "green mobility" claims. From 27 September 2026, manufacturers must disclose the system boundary (Scope 1-3) and methodology for every CO₂ claim. Particularly sensitive: "Zero Emission" advertising for electric cars is only permissible under EU law for local driving operation — battery production belongs to the supply chain and is not emission-free.
Typical claims in Automotive
- „climate-neutral mobility"
- „green diesel"
- „emission-free driving"
- „climate-friendly car"
- „CO₂-neutral drive"
- „zero emission"
- „sustainable SUV"
- „environmentally friendly hybrid"
- „green mobility transition"
- „CO₂-neutral delivery"
Concrete examples (red/amber)
- 'Climate-neutral vehicle' through CO₂ offsetting in reforestation projects
- 'Zero Emission' for electric cars without consideration of battery production (Scope 3)
- 'CO₂-neutral drive' without life-cycle assessment
- 'Climate-friendly diesel' through e-fuel blending (BGH 2023)
- WLTP values vs. real consumption — misleading with 'only 4.5 l/100 km'
Recognised certificates
Frequently asked questions
Can I still advertise 'Zero Emission' for electric cars?
Only with restrictions. Permissible is 'locally emission-free in driving operation' or 'Zero Tailpipe Emissions'. 'Zero Emission' as a blanket claim is misleading under Section 5 UWG and the EmpCo Directive (EU 2024/825), as battery production and electricity mix cause CO₂ emissions.
What does WLTP mean — and why are the values misleading?
WLTP (Worldwide Harmonized Light Vehicle Test Procedure) has been the EU-mandatory test standard since 2017. Real consumption is typically 20-30% higher. Therefore: state WLTP values, but add a note that real values vary depending on driving style and conditions.
Is CO₂ offsetting sufficient for a 'climate-neutral' drive?
No, from 27.09.2026 prohibited per se under EmpCo Annex I No. 4c. What is relevant under the directive is whether a reduction pathway is substantiated (illustrative example: 'CO₂ per vehicle reduced by X%') and whether any offsetting is shown only as a supplement with disclosed project methodology (e.g. Gold Standard, VCS).
What must be included in an LCA (life-cycle analysis)?
According to ISO 14067: goal and scope, system boundary (Scope 1-3), functional unit (e.g. per 100 km), data sources, assumptions, results, critical review (third-party review). Without these elements, the claim is not substantiated.
Empcora is a pure checking and documentation service and provides general information only on the legal situation based on the EmpCo Directive (EU 2024/825) and the unfair-competition / consumer-protection law transposing it in your jurisdiction including references. This is not individual legal advice and includes neither the rewriting nor the drafting of texts. No liability or warranty is assumed for the correctness, completeness or up-to-dateness of the analysis, nor for any legal consequences. The legal assessment of an individual case rests with an admitted law firm or lawyer.