Cleaning & Drugstore: Greenwashing Risk 2026

The cleaning and drugstore sector is particularly at risk of warnings due to the multitude of environmental claims and the direct targeting of environmentally conscious consumers. The EmpCo Directive (EU 2024/825) significantly tightens the requirements for transparency and substantiation of environmental claims from 27 September 2026. In particular, generic claims such as "environmentally friendly", "natural" or "biodegradable" without concrete substantiation violate Annex I No. 4a of the UCPD as amended by EmpCo and can lead to warnings. The BGH ruling of 27 June 2024 (I ZR 98/23 – Katjes) has already established that in the food sector "climate-neutral" without transparent disclosure of CO2 calculation and offsetting is misleading. This principle can be transferred by analogy to the cleaning and drugstore sector. The claim "climate-neutral" is from 2026 fundamentally inadmissible due to the per se ban in Annex I No. 4c UCPD as amended by EmpCo, even if CO2 offsetting takes place. In order to advertise in a legally compliant manner, it is essential to rely on recognised certificates such as the EU Ecolabel or the Blauer Engel and to provide these with the corresponding licence number. The mere use of buzzwords without substantiation is not sufficient and can lead to competition law consequences. In addition, a complete and correct INCI list (INCI nomenclature) on the packaging is mandatory to ensure transparency for consumers. The indication of the test standard for biodegradability (e.g. OECD 301) is also essential to substantiate the claim "biodegradable".