Sustainability and Packaging
Under the „Green Deal“, Europe aims to become the first climate-neutral continent
by 2050. A key element in realising this vision is the
Farm-to-Fork Strategy ,
which aims to align food production and distribution on sustainability, health and environmental awareness.
EmpCo Directive
Food companies must exercise caution when communicating their efforts in this regard to consumers. This is because part of the measures includes the
Empowering Consumers Directive (EU) 2024/825 (EmpCo Directive for short), which came into force in March 2024 and sets
out rules for environmental claims and sustainability labels. Since then, the
Third Act Amending the Act Against Unfair Competition (UWG) was published in the Federal Law
Gazette on 19 February 2026 to implement it in Germany.
The amendments define, in particular, the concept of an environmental claim, adapt the prohibition of misleading advertising accordingly, and expand the so-called ‘blacklist’
to include additional prohibitions. The following are now always prohibited
- General environmental claims
- Inaccurate information regarding the scope of an environmental claim
- Claims regarding the effects of offsetting greenhouse gas emissions, meaning: no more “climate-neutral” claims for mere offsetting
- The use of sustainability labels without a certification system
At the same time, the law tightens the requirements for future promises. A key prerequisite for claims regarding future environmental performance is a publicly accessible and realistic implementation plan.
PPWR
As another key pillar of the Green Deal, all types of packaging are to follow a harmonised sustainability strategy. To this end, the EU published
Regulation 2025/40 on packaging and packaging waste
Regulation 2025/40 on packaging and packaging waste (Packaging and Packaging Waste Regulation, or PPWR for short) in January 2025. This applies directly in all Member States from August 2026 and brings far-reaching changes for businesses.
The PPWR sets out in unprecedented detail who bears which responsibilities within the packaging supply chain. It regulates both requirements for the labelling and conformity of packaging and the principles for deposit-refund schemes and recyclability requirements. New obligations arise in particular for producers and manufacturers, but also for other players in the supply chain. These include specific requirements for technical documentation and reporting formats, as well as measurable limits for void space or minimum recycled content. In addition, there are bans on certain substances, in particular PFAS and bisphenols, as well as mandatory compostability for certain tea and coffee bags.
Consultancy service
We are happy to assist you in reviewing your advertising campaigns or help you understand your role in packaging production. Whether you need a brief clarification or a comprehensive review, we provide professional support. Together with you, we will find the balance between greenwashing and inspiring marketing communication. You will receive legally sound and practical advice that highlights both opportunities and risks.
With regard to problematic substances, we also offer joint consultancy with meyer.science.