EmpCo in 50 steps

Common mistake: Sub-domains such as shop.company.com or blog.company.com are forgotten — these must be scanned separately.

Common mistake: Images, alt texts, and meta descriptions are not searched — title tags and OpenGraph descriptions must also be checked.

Common mistake: Only the company website is checked — press releases on third-party platforms and affiliate texts are overlooked.

Common mistake: Only one person is named as "greenwashing officer" without a deputy arrangement — responsibility disappears during holidays or absence.

Common mistake: The sector is classified too broadly — within one sector there are products with both high and low risk.

Common mistake: What competitors do is NOT the benchmark — even if everyone writes "climate-neutral", it remains prohibited from 27.09.2026.

Common mistake: Outdated certificates are not removed — evidence older than 24 months is generally no longer considered current.

Common mistake: Only formal legal letters are counted — consumer-protection complaints and competition-authority notices are equally relevant.

Common mistake: The score is recorded once and not measured again regularly — it must be monitored weekly.

Common mistake: Marketing acts without management backing — internal conflicts over "softer" copy are foreseeable.

Common mistake: The term remains in sub-domain PDFs, old newsletters, or meta titles.

Common mistake: Instead of a factual description, soft synonyms such as "climate-friendly" are used — these are equally problematic.

Common mistake: Logistics partners are not informed that their standard texts are equally problematic.

Common mistake: Animal welfare claims are forgotten in image captions — image descriptions must also be checked.

Common mistake: Individual ingredients are advertised as "organic" even though the finished product does not carry organic certification.

Common mistake: "Natural" is replaced by "from nature" or "natural ingredients" — these formulations are equally problematic.

Common mistake: Theoretical recyclability is confused with actual recovery — e.g. for composite materials.

Common mistake: Logos are used without additional text — the consumer cannot identify the label.

Common mistake: The term "sustainable" is simply replaced by "responsible" or "conscious" — these synonyms are equally problematic.

Common mistake: Comparison without a clear reference point — "less energy" without stating the baseline is not sufficient.

Common mistake: The "Eco" element of brand names is taken as given — even here a justification is required.

Common mistake: Comparison is made using outdated industry averages — data older than 36 months should no longer be used.

Common mistake: Relies on supplier self-declarations without independent verification — these are insufficient for "fair" claims.

Common mistake: Vague self-commitments are cited that do not define concrete standards.

Common mistake: Region is defined differently for each product — a company-wide uniform definition is required.

Common mistake: Copywriters defend the term as "purely promotional language" — UWG case law says otherwise.

Common mistake: General health claims are used without checking for an EFSA reference.

Common mistake: Habitual catchphrases in advertising copy are not recognised — a separate list of banned phrases helps.

Common mistake: Own Excel calculations without a recognised standard — these will not hold up in legal proceedings.

Common mistake: Only one product is analysed and results are applied to the entire range — this is not permissible.

Common mistake: Self-declarations are accepted without spot-checks — at least 10% of suppliers should be verified.

Common mistake: Evidence is scattered across email attachments — a central filing system is mandatory.

Common mistake: The CMS overwrites old versions without archiving — in the event of litigation there is no evidentiary basis.

Common mistake: The study disappears from the server — and with it the evidence.

Common mistake: The methodology page is not linked from the homepage — consumers cannot find it.

Common mistake: Checks are carried out but not documented — in litigation the due-diligence documentation is decisive.

Common mistake: There is only an end goal but no plan — this falls under an impermissible future claim.

Common mistake: The plan is not publicly available — the commitment is then legally vulnerable.

Common mistake: Reporting is not updated annually — old commitments become stale and turn into a liability.

Common mistake: Interim targets are not communicated in marketing — only the attractive end goal is visible.

Common mistake: When a target is missed, the commitment is quietly adjusted without communication — this is considered misleading.

Common mistake: Labels continue to be used even though the certification has not been renewed.

Common mistake: Own logos are perceived as "neutral labels" — even if developed in-house.

Common mistake: Logo is used without additional information — the consumer cannot verify the label.

Common mistake: The scope of certification is extended to products not covered by it.

Common mistake: Assumption that national labels are internationally understood.

Common mistake: Monitoring only runs on the main domain — new sub-domains and microsites are not covered.

Common mistake: External agencies are not trained — they produce copy that is not compliant.

Common mistake: The process is too slow and gets bypassed — it must be fast enough not to become a bottleneck.

Common mistake: Compliance remains operational and never reaches management level — in a crisis the strategic backing is missing.