Private sustainability label
May qualify if supported by a certification scheme meeting the required transparency, independence and monitoring conditions.
BuVNK · EmpCo · Sustainability labels · Updated 14 October 2026
Sustainability labels and certification: EmpCo 2026
Which eco-labels and sustainability marks may businesses still display? Practical guidance for marketing, product management and compliance, with official sources.
Since 27 Sep 2026Consumer-facing sustainability labelsCheck the label’s legal basis
Important: Since 27 September 2026, the EmpCo rules on sustainability labels apply in consumer-facing marketing. Displaying a sustainability label which is neither based on a certification scheme nor established by public authorities is prohibited (point 2a in Annex I to Directive 2005/29/EC, as amended). Even otherwise eligible labels must not be used misleadingly. This page offers general information, not legal advice.
01 / Legal basis
What counts as a sustainability label?
EmpCo addresses voluntary trust marks, quality marks and equivalent signs promoting a product, process or business through environmental or social characteristics. Labelling that is mandatory under EU or national law is not covered merely because it has an environmental theme.
Public-authority label
A sustainability label established by a public authority may meet the separate statutory route. The origin and permitted use must still be verified.
Self-created “eco” badge
A green leaf designed in-house is risky where consumers would understand it as a sustainability quality seal yet no qualifying scheme or public authority stands behind it.
02 / Certification schemes
What must a certification scheme provide?
The Directive sets minimum conditions. Businesses should request evidence of the following from the scheme owner:
Published terms
The rules and requirements for using the label are public and understandable.
Fair access
Access is open on transparent, fair and non-discriminatory terms to businesses able to satisfy the requirements.
Expert input
Criteria are developed with relevant experts and stakeholders.
Independent verification
Compliance is monitored by a third party independent of the scheme owner and certified trader, with appropriate competence.
Enforcement mechanisms
Non-compliance processes include suspending or withdrawing the right to use a label.
Current supporting evidence
Valid certificates, reports, scope, expiration and relevant changes are checked before making marketing claims.
03 / Examples
Understanding common examples
These examples are illustrative. Lawful use still depends on the actual claim, licensing conditions and overall consumer impression.
EU Ecolabel
An official EU environmental label operating under the relevant EU regulatory framework. Use requires compliance with the specific product criteria and licensing conditions.
Blue Angel (Blauer Engel)
A German public-sector environmental label supported by established award criteria. Product scope, current requirements and valid use rights still matter.
ISO 14001 / ISO 50001
Management-system certifications can be relevant evidence. They do not by themselves authorise a self-created product sustainability seal or broad environmental claims.
In-house “Eco” logo
Where presented as a voluntary sustainability label, an unsupported self-declaration will not suffice; an eligible basis is needed.
04 / Claim scope
Certification is not the same as a marketing claim
A certified management system, a certified product and a green symbol on packaging can communicate very different things.
| Subject of the audit | Was the product, process, management system or only a particular dataset assessed? |
| Right to display | Is the precise label authorised for this product and market? |
| Scope | Which products, sites, performance criteria and periods are covered? |
| Claim | Does the advertisement communicate only what was verified, rather than implying additional benefits? |
| Consumer perception | Does the visual presentation suggest independent overall approval when none exists? |
05 / Label checklist
Seven steps for a sustainability-label audit
Review every mark used in online shops, packaging, brochures and product advertising – including existing materials.
01
Create a label inventory
List sustainability marks, logos and badge-like visuals by product and advertising channel.
02
Classify the claim
Is it a voluntary sustainability label? Which environmental or social advantage does it appear to communicate?
03
Identify its legal basis
Was it established by a public authority or supported by a qualifying certification scheme?
04
Check rules and auditor
Document published criteria, independent third-party oversight, access conditions and suspension procedures.
05
Verify validity and scope
Check the licence, product/site applicability, assessment dates and term.
06
Review the complete advertisement
Could imagery, claims and footnotes suggest more than the verification supports?
07
Record approval
Keep reviewer, evidence, decision, any remediation and re-check date.
06 / FAQ
Frequently asked questions about sustainability labels
Are all private eco-labels banned from 2026?
No. Private labels can qualify where they are based on a certification scheme that meets the statutory conditions. The use must also be non-misleading.
Is a company’s self-declaration enough?
An unsupported self-declaration does not replace the required certification scheme or public-authority basis for a voluntary sustainability label in consumer-facing marketing.
May a business mention ISO 14001 certification?
A truthful statement about a valid management-system certificate must be assessed separately from a product eco-label. Marketing should specify the actual scope and avoid misleading consumers.
Must every sustainable product carry the EU Ecolabel?
No. EmpCo does not mandate EU Ecolabel certification for every product; it regulates how voluntary sustainability labels may be displayed.
Do the rules cover social labels?
Yes. The definition covers environmental and social characteristics, or both.
What about mandatory labels?
Labels mandated under EU or national law are excluded from the definition of voluntary sustainability labels, though separate marking rules may apply.
BuVNK / EmpCo
Further EmpCo and BuVNK guidance
07 / Sources
Official law and supporting guidance
EU Directive 2024/825 – Official text ↗eur-lex.europa.euEuropean Commission – EmpCo Q&A (22 Sep 2026) ↗commission.europa.euGerman Environment Ministry – Blue Angel and EmpCo rules ↗www.bundesumweltministerium.deEuropean Commission – EU Ecolabel ↗environment.ec.europa.euEuropean Commission – Green Claims (legislative proposal) ↗environment.ec.europa.eu
BuVNK · EmpCo
Review sustainability labels with confidence
Want to organise your label inventory, supporting claims and internal approvals? BuVNK provides guidance on verifiable sustainability communications.