There’s a certain irony to this story. Johannes Gutenberg used his press to print not only Bibles but also letters of indulgence, physical certificates confirming that someone had eased their conscience financially. Around 570 years later, the European Union is putting an end to exactly this kind of “business model”. And once again, the printing industry finds itself right in the middle of it — this time, however, on the customer side.
From 27 September 2026, the label “climate-neutral printed” could become a problem. Anyone who has so far offset the CO2 generated during production and printed the result on the sheet will need something more from then on — and something considerably more uncomfortable: proof.
What’s happening, short and painless
EU Directive 2024/825, EmpCo for short, has been transposed into German law. The Third Act Amending the Gesetz gegen den unlauteren Wettbewerb (“Act Against Unfair Competition,” UWG) was signed on 12 February 2026, announced on 19 February 2026 (BGBl. 2026 I Nr. 43) and must be applied from 27 September 2026. The new prohibitions are set out in the annex to Section 3(3) UWG. That’s the blacklist. No weighing up, no case-by-case assessment, no “yes, but we meant it differently”. Blacklist. At least the colour fits.
Four points that affect the industry directly:
- Compensation no longer confirms neutrality. The Bundesverband Druck und Medien (“German Printing and Media Industries Federation,” bvdm) puts it unambiguously: “climate-neutral printed” is “prohibited insofar as it relies solely on the compensation of greenhouse gas emissions”.
- Generic claims need evidence. “Environmentally friendly”, “green”, “sustainable” only work now with a verifiable, recognised basis.
- Home-made seals are not permitted. Certification systems with transparent criteria and independent monitoring remain permitted. Blue Angel: yes. EU Ecolabel: yes. The leaf symbol the intern knocked up in Illustrator in 2011: no.
- Future promises need a plan. “Climate-neutral by 2030” requires measurable, publicly accessible targets with interim steps and external verification. A paragraph in the sustainability flyer isn’t enough.
Dr Carsten Föhlisch of Trusted Shops sums it up in e-commerce magazin: “Terms like ‘climate-neutral’ or ‘sustainable’ will only be permissible in future if companies can demonstrably prove exactly what is meant.” A small detail for fans of dramatic timing: 27 September 2026 is a Sunday. Anyone still wanting to tidy up their shop has until Saturday evening. Warning-letter law firms, as experience shows, get to work on Mondays.
No, this isn’t a German problem
The thought that probably occurs to most people first: typical German over-regulation. But this time it isn’t even remotely true. EmpCo is an EU directive. It applies from 27 September 2026 in all 27 member states. The transposition deadline expired on 27 March 2026, and this is where it gets interesting: on 28 May 2026, the European Commission sent letters of formal notice to 20 member states because they hadn’t delivered. The list included, among others, France, Spain, Austria, the Netherlands, Belgium, Poland, Portugal, Sweden and Finland.
Germany was not on this list. Let’s let that sentence sink in for a moment.
According to the CMS Implementation Tracker (as of 20 July 2026), the countries that have transposed the directive include Germany, Italy with Legislative Decree 30/2026 of 9 March 2026 and the AGCM as enforcement authority, Ireland with S.I. No. 124 of 2026, and Hungary.
And outside the EU? Switzerland, not otherwise known for regulatory haste, was faster than everyone. The new Art. 3(1)(x) of the Swiss UWG was passed by parliament on 15 March 2024 and has applied since 1 January 2025 — with a reversed burden of proof: anyone making a climate claim must have the evidence at the moment the claim is made, not only once a dispute arises. In the UK, the CMA and the DMCC Act are working on the same question.
France already had its own rules on neutrality claims in advertising before EmpCo, set out in Décret n° 2022-539 of 13 April 2022. This put the country ahead of the then EU standard, though only on this one point: anyone advertising CO₂ neutrality has to disclose their emissions balance and reduction pathway. EmpCo demands more, and demands it in more places. This is exactly what explains the letter of formal notice from Brussels: what was criticised was not the absence of rules, but the failure to notify complete transposition.
The requirements for online printers are rising
For online print, this is the real story, and it’s an uncomfortable one. Online print is the most international segment of the printing industry. Anyone shipping from Germany to France, Italy or Switzerland is subject to the law of the market in which they advertise, not the law of where their company is based. A shop with twelve language versions potentially has, from September, twelve separate claims regimes, coming into force at different times and differing from one another in the details.
And because I don’t dress facts up to look better than they are, a confession: I’m not sure myself about France’s state of transposition. The Commission sent Paris a formal notice at the end of May; the CMS tracker lists France as having transposed as of 20 July. Presumably something was delivered in between. I can’t prove it. So anyone currently planning French landing pages should please check the current status on the day, and trust neither me nor a tracker.
That, incidentally, is the real problem: the patchwork is currently changing week by week. The directive was meant to harmonise the single market. In the short term, what it’s mainly harmonising is the delay.
Let’s be honest with ourselves
Before the printing industry unanimously points the finger at Brussels, a brief bit of self-examination.
“Climate-neutral printed” was something like the organic seal of offset printing. Everyone wanted it, almost no one asked what exactly it stood for. There was a phase when every other print shop logo was decorated with a leaf — some had three at once — and the colour green was scarcer in the industry than 300gsm board. You could have a coffee at a trade fair and hear four definitions of climate neutrality in the process, no two of which were compatible. None of this was ever meant maliciously. It was convenient. You paid an annual fee, got a number, a logo and a good feeling, and the best part: it worked in sales. Just not as environmental protection — as a selling point. I don’t exempt myself from this. On more than a few slides I’ve shown myself, the word “climate-neutral” appeared without a footnote. In that sense, EmpCo also sets us a collective piece of homework.
What the bvdm is doing, and why that’s the real point
The bvdm has been working on two fronts for over a year now. On the political side, it has been demanding since July 2025: one-to-one transposition without national gold-plating, application only in B2C and not in B2B, economically viable review intervals instead of an annual review obligation, recognition of the seals of the Klimainitiative (“Climate Initiative”) in the statement of legislative intent, and sell-off periods for packaging, printed products and books.
On 30 April 2026, it became more explicit. Kirsten Hommelhoff, Director General of the bvdm: “Without transitional periods, flawless products and materials risk being destroyed. That is neither economically viable nor ecologically sensible.” And further: “The federal government must now push hard for a workable solution at EU level.”
She’s right. A law against greenwashing that results in flawless folding cartons being shredded because they carry a word that, from a Sunday at the end of September, is no longer allowed to appear on them, has a design flaw. Burning the environment for the environment’s sake: that’s the kind of logic that emerges when lawyers and ecologists don’t sit down together in time.
The catch: that’s an argument for sell-off periods, not against the rule itself.
More important than any statement, in any case, is what the association is doing operationally in parallel. The bvdm is reviewing its own certification system so that the Klimainitiative’s seals remain legally viable even after the deadline, and published an FAQ guide for members in July 2026. That sounds like trade-association work in its most tedious form. But it’s a question of survival for a large part of the industry. According to the bvdm, around 83 percent of its roughly 6,000 member companies employ fewer than 20 people. These companies aren’t building externally verified climate accounting. Either there’s a collective solution, or from September they simply say nothing at all on the subject of the environment.
And now for the good news
First, substance finally wins. Anyone who has genuinely invested — in more efficient machines, their own photovoltaics, real green electricity, the Blue Angel, mineral-oil-free inks, recycled paper — is allowed to say so and prove it from September onward. Anyone who merely bought the claim by bank transfer stands to one side and stays quiet. For twenty years, both looked equally green in the brochure. This injustice ends on the stated deadline.
Second, the environmental claim becomes a data question, and that’s a home game for print. A provable statement about product, life-cycle phase, source and time period is nothing other than a product attribute. Product attributes belong in the PIM, in the costing, in the API, in the quote data record. Anyone able to calculate paper, energy and process per job will in future be selling a figure instead of an adjective. Figures can be automated. Anyone can copy an adjective.
Third, a consulting business emerges out of nowhere. Every print shop knows what’s printed on its customers’ packaging. Anyone who now goes through it and tells the client which print run becomes a problem from 27 September is selling reprints and redesigns, rather than fielding complaints in December. Liability sits with the customer. The print shop is allowed to warn them. Rarely has looking out for a customer been so easy to put a price on.
Fourth, it cleans up the market. The environmental debate in print has run on assertion for twenty years. Now there’s a European benchmark. The fact that the separate Green Claims Directive was halted changes nothing about this. EmpCo is applicable law, and anyone waiting for it to disappear again is backing the wrong horse.
What online printers must do NOW
Nine points. The effort involved: manageable. The alternative: a letter from a lawyer.
1. A claims audit across everything that contains text. Shop, product detail pages, filters, category descriptions, checkout, footer, newsletter, autoresponder, quote PDFs, trade show stands, package inserts, email signatures. Yes, including the welcome email originally created back in 2019. Hardly anyone actually reads it, but it counts.
2. Assign evidence to every claim. Rule of thumb: if the answer starts with “we’ve got a certificate somewhere” and nobody then knows where it is, the claim is already dead.
3. Compensation out, reduction in. Instead of “climate-neutral printed”, get specific: recycled paper with the Blue Angel, green electricity in production, mineral-oil-free inks, stating product, life-cycle phase and source. Less poetic, but legally sound and true.
4. Retire the green leaf. Home-made eco-badges without a certification system behind them are impermissible from September. A brief moment of silence, then delete.
5. Don’t forget the checkout. “CO2-neutral shipping” is the same offence, just further down the funnel. And that’s exactly the spot nobody ever looks at in internal audits — though the enforcement authority just might.
6. Check country and language versions individually. The French template is not the German template. Marktortprinzip (“market-location principle”): the law of the market in which the advertising takes place applies. France has had its own rules on neutrality claims since 2022, which have presumably since been extended further. Switzerland has been applying its requirements since January 2025, reversed burden of proof included.
7. Write to customers whose printed claims are about to fall foul of the rules. The only point on this list that makes money instead of costing it. Anyone who knows which of a customer’s print products become a problem from September sells reprints in the autumn instead of having to grant goodwill gestures in winter.
8. Name one person who is allowed to say no. No claim goes live without someone with a backbone having looked at it. That’s the entire governance structure this needs. No tool replaces it, and neither does a workshop.
9. Mark 26 September boldly in the calendar. A Saturday. The last working day before the official deadline, which falls on a Sunday. From the following Monday, the staff at the warning-letter law firms are back in the office.
Is a new wave of warning letters now heading for online print?
Short answer: probably not a wave, but targeted barrage fire. Here’s the status quo in five statements.
In favour of that: the new prohibitions are on the blacklist. No weighing up, no assessment of interests, a screenshot is enough. And a script that searches three hundred shops for “climate-neutral” can be written in an afternoon. The most expensive part of any warning letter — finding the violation — falls away.
Against that: the 2020 Anti-Abmahngesetz (“Act against Abusive Warning Letters”) effectively dried up the mass-market business built around imprint notices and withdrawal information. Trade associations now have to be listed with the Bundesamt für Justiz (“Federal Office of Justice”), and abuse of rights has become considerably harder. The subject is also too unwieldy for form-letter campaigns, since environmental claims require more scrutiny than a missing mandatory disclosure.
Where it really gets expensive: not with the warning letter itself, but with the cease-and-desist declaration that follows. Whoever signs it is liable for a contractual penalty on every repeat occurrence. And a shop with several thousand product pages, filters, data sheets and automated mailings is operationally hard to get completely clean. A forgotten category text from 2021 can end up costing more than the warning letter that triggered it. Before signing, the lawyer and IT belong at the table together, not one after the other.
On the fines currently being predicted: Section 19 UWG provides for up to €50,000, and for annual turnovers above €1.25 million, up to 4 percent of annual turnover, capped at €2 million. That sounds dramatic, but it only applies to widespread infringements with a Union dimension, within the framework of coordinated enforcement action. For a print shop with one unfortunate word in its footer, that isn’t a realistic scenario. Anyone using these figures to scare people usually has something to sell. And the real point: the most dangerous warning letter doesn’t come from the lawyer you’ve never heard of. It comes from the colleague you know from the trade fair. Anyone who has cleaned up their own act and lost a selling point in the process won’t be keen, from 28 September, to watch a competitor go on using it. That incentive comes from within the industry itself, and it’s stronger than any trade-association interest.
My Take: Let’s speak plainly: the outcry in the industry isn’t about environmental protection. It’s about the loss of a selling point. You’re allowed to say that without accusing anyone of bad intent. But you should at least name it honestly before signing the next position paper. Anyone who has rented an environmental image for twenty years shouldn’t be surprised when the lease runs out.
Anyone who realises on 28 September that they have a problem never had a compliance problem — they had a leadership problem. The directive dates from February 2024. The German law has been in the Bundesgesetzblatt (“Federal Law Gazette”) since February 2026. That’s two and a half years’ lead time. Anyone who let that time pass isn’t a victim of Brussels — they made a management decision. Namely, to sit it out.
Waiting for the association isn’t a strategy. The fact that the bvdm is overhauling its certification system is right and important, and for thousands of small businesses it’s the only realistic option. But a new seal isn’t a new argument. At best, it’s the ticket to entry. Anyone who delegates their entire sustainability profile to a collective label will, even after the overhaul, have nothing that distinguishes them from the competitor carrying the same label. The association can offer the licence. How a company’s own efforts turn back into a USP is entirely in that company’s own hands.
The fact that Germany was on time is a competitive advantage that comes along rarely enough. While twenty member states received formal notices from the Commission, German providers had seven months’ head start. Anyone who used it will, come October, be the only one in the European market able to deliver robust claims while the competition in Madrid and Warsaw is still sorting itself out. That’s a window of opportunity, not a permanent state. It closes in 2027.
And the most uncomfortable realisation to close with. The question printing companies are asking themselves is: what am I actually still allowed to say? But that’s the wrong question. The right one is: what can I actually measure? Anyone without an answer to that never had an environmental strategy. They had environmental communications. Full stop.
In the meantime, would policymakers please deliver the sell-off periods promptly — before September, not after the fact. An environmental law that destroys resources hands its opponents the ammunition free of charge.
