14 July 2026 · Legal position as of: October 2026

Greenwashing: the UWG rules in force since 27 September 2026

On 7 July 2026 the Austrian parliament passed the amendment to the Unfair Competition Act (UWG) implementing the European EmpCo directive (BGBl. I No 58/2026). The new rules have applied since 27 September 2026 and change the requirements for every form of environmental and sustainability advertising.

What has been prohibited since 27 September 2026

  • Generic environmental claims such as "climate-neutral", "eco-friendly", "green" or "sustainable" are inadmissible where the claimed outstanding environmental performance is not demonstrated.
  • Sustainability labels may only be used if they are based on a certification scheme or awarded by public authorities; self-invented labels are prohibited.
  • Future promises ("climate-neutral by 2030") require a public, verifiable implementation plan.

Who is affected

Every company that advertises environmental characteristics of its products, services or the company itself is affected, from the webshop banner to packaging to the sustainability page of the website. The amendment contains a controversial transitional provision: for three years, civil claims concerning goods may be brought only in respect of goods placed on the market after 27 September 2026. Relying on it is unwise, not least because competitors and associations can act under the general prohibition of misleading practices.

What to do now

If you have not yet done so, carry out a stocktake now: which environmental claims does your company use, where, and which can be substantiated with recognised evidence? Replace any claims without proof or make them specific. "Packaging made from 80% recycled material" remains permissible; "eco-friendly packaging" has not been permissible since 27 September 2026. We review advertising materials, packaging and web presence and say concretely what can stay and what must change.

This information is general in nature and does not replace legal advice on an individual case.

More on this practice area: Competition & Antitrust Law