EmpCo Directive (EU) 2024/825

EmpCo Scanner: find greenwashing risks on your website

Since 27 September 2026, the rules introduced by EmpCo have applied throughout the EU. In Germany, they have been transposed through the amended UWG. The EmpCo Scanner automatically analyses your website against key EmpCo requirements and points out claims that appear risky.

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Why scan?

Why the EmpCo scan matters now

The EmpCo Directive (EU) 2024/825 has applied in all EU member states since 27 September 2026. In Germany, it has been transposed through the amended UWG. Several practices relating to environmental claims are now on the blacklist in the Annex. For companies, private enforcement is particularly relevant: certain competitors, qualified trade associations and qualified consumer associations can assert claims for removal and injunctive relief under the conditions of Section 8 UWG. Legal proceedings may be preceded by a formal warning letter (Abmahnung). Companies should therefore identify potentially problematic environmental claims promptly and examine them internally.

Free · No credit card · Results in 10-15 min.

New bans on environmental claims

No. 4a of the Annex covers generic environmental claims such as “environmentally friendly” where recognised excellent environmental performance relevant to the claim cannot be demonstrated. No. 4c of the Annex covers claims, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions. Subject to the respective conditions, these practices are deemed unfair without a case-by-case assessment.

Actions by associations and warning letters

Qualified trade and consumer associations can take action against unlawful environmental claims under the conditions of Section 8 UWG. An action for an injunction may be preceded by a formal warning letter (Abmahnung).

Turnover-based fines for widespread infringements

In the case of a widespread infringement under Section 5c(1) of the amended UWG, turnover-based fines under Section 19 of the amended UWG can be imposed as part of a coordinated CPC enforcement action under Art. 21 of Regulation (EU) 2017/2394. They do not follow automatically from every EmpCo infringement.

Evidence instead of gut feeling

What matters from now on is the evidence: green claims require sound substantiation, from the product page to the advertisement.

Free, no registration required

The EmpCo scan is free of charge and does not require a user account. You receive selected findings with probability scores and severity levels as a basis for internal discussions.

Evidence instead of assertions

If environmental claims are not sufficiently substantiated, the scan can flag passages where no sufficient evidence is apparent on the scanned page. The finding can serve as a basis for examining claims internally and adjusting them where necessary.

Areas of analysis

What the EmpCo Scanner analyses

The scanner analyses texts and indications of labels automatically. It can classify potentially problematic claims as findings and compare them with key EmpCo requirements. In doing so, it can flag passages where evidence is not apparent on the scanned page.

EmpCo Scanner for generic environmental claims

Generic terms such as “environmentally friendly”, “green” or “sustainable” that are not justified by recognised excellent environmental performance (No. 4a of the Annex).

EmpCo Scanner for promises about the future

Claims such as “climate neutral by 2030” for which no clear and verifiable implementation plan is apparent on the website.

EmpCo Scanner for climate neutrality claims

Claims, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions (No. 4c of the Annex).

EmpCo Scanner and sustainability labels

Sustainability labels that are neither based on a certification scheme nor established by public authorities.

EmpCo Scanner for text claims and label indications

Text claims and indications of labels can be output as findings at the passages detected by the scan.

EmpCo Scanner shows severity levels, not verdicts

The evaluation shows selected findings with probability scores and severity levels as a working basis, not as a legal verdict.

How it works

Your findings in three steps

Enter URL

Enter your website address and your email address in the form to start the scan.

Automated check

Your reachable pages are automatically checked against key EmpCo requirements.

Evaluate findings

You receive selected findings with probability scores and severity levels as a basis for internal discussion and, where necessary, for legal advice.

Frequently asked questions

Frequently asked questions about the EmpCo Scanner

What is an EmpCo scanner?

An EmpCo scanner is a tool that automatically analyses websites for environmental claims that could breach the new advertising bans introduced by the transposition of EmpCo. It delivers selected findings with probabilities, but no legal verdicts.

Is the EmpCo scan really free?

Yes. The scan of your website is free of charge and does not require a user account. For in-depth analysis and documentation, the EmpCo Manager is available as a paid product.

What changed on 27 September 2026?

Since this date, the EmpCo requirements have applied throughout the EU. In Germany, the Third Act amending the UWG (German Act against Unfair Competition, BGBl. 2026 I No. 43) now applies in full. The practices specifically described are, subject to the statutory conditions, deemed unfair without a case-by-case assessment.

Does the scanner replace legal advice?

No. The tool delivers findings and probabilities as a basis for documentation. For a final legal assessment, we recommend seeking advice from a lawyer, for example one specialising in unfair competition law.

Can the scanner determine whether the law has been infringed?

No. The scanner can flag passages where no sufficient evidence is apparent on the scanned page. Whether a specific claim is unlawful depends on the individual case and, in the event of a dispute, is decided by a court.

Which claims have become problematic?

These include generic environmental claims under No. 4a of the Annex for which recognised excellent environmental performance relevant to the claim cannot be demonstrated, product-related claims of climate neutrality based on greenhouse gas offsetting under No. 4c of the Annex, sustainability labels that are neither based on a certification scheme nor established by public authorities, and certain claims about future environmental performance without a verifiable implementation plan.

Does EmpCo also apply to smaller companies?

The EmpCo requirements apply throughout the EU and, in principle, also cover smaller companies. In Germany, certain competitors, qualified trade associations and qualified consumer associations can assert claims for removal and injunctive relief under the conditions of Section 8 UWG. Legal proceedings may be preceded by a formal warning letter (Abmahnung).

What happens after the scan?

You review the findings displayed, prioritise problematic passages internally and adjust claims where necessary. The time of the scan can also be included in your internal documentation.

Scan your website and view the findings

Check your website against key EmpCo requirements now, free of charge and without a user account.

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All about the EmpCo Scanner

10 questions and answers about the EmpCo Scanner

What is the EmpCo Scanner and how does it work?

The EmpCo Scanner is a browser-based tool that examines websites for potentially problematic environmental claims. It is aimed at companies that use green claims in marketing, on product pages and in corporate communications. The scanner processes detected text claims and indications of labels and maps possible findings to key EmpCo requirements. The result is an initial evaluation with selected findings, probability scores and severity levels.

Each result displayed is presented clearly for an initial internal review. The results do not claim to be complete. To run the scan, enter the website URL and your email address. The results are usually available after 10 to 15 minutes.

No user account is required. You receive indications of detected passages, which you can then examine internally. For a final legal assessment, we recommend seeking advice from a lawyer.

What is the EmpCo Scanner and how does it work?

Why is the EmpCo Scanner relevant now?

Since the EU application date of 27 September 2026, the rules introduced by EmpCo have applied throughout the EU. In Germany, the amended UWG (BGBl. 2026 I No. 43) now applies in full. No further transition period is provided for. The EmpCo Scanner helps companies to examine any problematic passages it displays as early as possible.

Revising website copy takes time, from editorial correction to approval. The earlier findings are available, the more smoothly the process can be managed. The scan provides a working basis on which the findings displayed can be prioritised internally and, where necessary, assessed legally before any warning letters or cease-and-desist demands from associations entitled to bring claims.

Companies should align their website with the applicable national transposition. The EmpCo scan helps them to start this process. The final legal assessment remains a matter for the individual case.

Who should use the EmpCo Scanner?

The EmpCo Scanner is aimed at companies that use environmental claims in their communications. Typical users are online shops with product pages that contain terms such as “natural”, “green” or “recyclable”. Agencies can also scan their clients’ websites and evaluate the findings displayed internally.

Marketing and compliance managers use the scan to record in a structured way where risks could lie. The same applies to start-ups and smaller brands that have not yet established their own routine for this check. The evaluation shows which of the captured claims stand out. It helps teams to compare the findings displayed with the associated evidence internally.

Shops with many catalogue pages benefit in particular, because reachable pages are analysed automatically. The findings are prepared for an initial internal review. For a final legal assessment, we recommend seeking advice from a lawyer.

Why should I run the EmpCo scan now?

The prohibition of misleading commercial practices under Section 5 UWG already applied before EmpCo and still applies; in addition, stricter requirements for environmental claims have applied since 27 September 2026. Warning letters and cease-and-desist demands from competitors or associations entitled to bring claims are possible under current law. The EmpCo Scanner analyses the website against key standards of the new rules.

The sooner you start, the better you can plan corrections and avoid short-notice changes under time pressure. The free scan provides an initial working basis with selected findings for this purpose.

Passages displayed can be prioritised internally. Passages that are not displayed are not automatically free of risk. For individual legal questions, we recommend seeking advice from a lawyer.

How does the EmpCo Scanner work in detail?

After you have entered your website URL and email address, the EmpCo Scanner starts an automated process. While the reachable pages of your website are loaded and analysed for content, the system captures text claims and indications of labels used. Automated procedures map possible findings to key EmpCo requirements. The findings contain probability scores and severity levels.

The result is not a blanket verdict but shows a selection of the processed findings. This lets you see which of the passages displayed may require further clarification. The findings displayed serve as a basis for internal discussion and, where necessary, for advice from a lawyer.

The results are usually available after 10 to 15 minutes. You can then prioritise the findings displayed internally. For a final legal assessment, we recommend seeking advice from a lawyer.

How does the EmpCo Scanner work in detail?

Which claims can the EmpCo Scanner display as findings?

The EmpCo Scanner searches for environmental claims that could be covered by new EmpCo rules. These include generic terms such as “environmentally friendly” or “sustainable” if they are not justified by recognised excellent environmental performance (No. 4a of the Annex). Claims that a product is climate neutral on the basis of CO₂ offsetting can also appear as possible findings under No. 4c of the Annex. Promises about the future such as “emission-free by 2030” can be analysed as to whether a verifiable plan is apparent.

Sustainability labels that are neither based on a certification scheme nor established by public authorities can also appear as possible findings. The analysis focuses on text claims and indications of labels. The passages displayed are given probability scores and severity levels, not a legal verdict.

The free results page shows up to three teaser findings with a probability score and severity level, up to three further findings in blurred form, and detected labels or label findings. It therefore represents a selection of the processed results, not a complete overview. For a final assessment, we recommend seeking advice from a lawyer.

Which claims can the EmpCo Scanner display as findings?

What does the EmpCo Scanner cost?

The EmpCo scan is free of charge and does not require a user account. After you enter your website URL and email address, the results are usually provided within 10 to 15 minutes. This gives you an initial overview without obligation. The free results page shows up to three teaser findings, up to three further findings in blurred form, and detected labels or label findings.

In the paid EmpCo Manager, you can work on findings, documentation and reports together. You can find the range of functions and prices on our pricing page. The free scan serves as an initial assessment. Based on the results, you decide whether an in-depth analysis makes sense.

The free scan does not create a paid subscription. The EmpCo Manager, too, provides findings, not legal advice. For a binding assessment, we recommend seeking advice from a lawyer.

Where does the EmpCo Scanner find greenwashing risks on your website?

Greenwashing risks are found not only on the home page but often also on product pages, in category menus or on the “About us” page. This also includes publicly accessible content rendered on the pages reached by the scan. Terms such as “sustainable”, “climate neutral” and “100% recyclable” appear particularly frequently. Internally, teams often associate a term with a specific meaning that may be understood differently from the outside.

The EmpCo Scanner automatically searches reachable pages and outputs detected environmental claims as findings with probability scores and severity levels. This means that passages that might be overlooked in a conventional editorial check can also stand out. Passages that are not displayed are not automatically free of risk.

Older texts in particular may contain claims that are no longer on the team’s radar. Starting from the URL entered, the scan can also provide indications of such passages. The results remain probabilistic findings and do not claim to be complete.

Where does the EmpCo Scanner find greenwashing risks on your website?

Why do I need the findings from the EmpCo Scanner?

The findings document possible problem areas and show the passages in which environmental claims were detected. This allows the findings displayed to be assigned specifically to marketing, editorial, legal or purchasing. The findings displayed contain probability scores and severity levels. They serve as an initial working basis for examining flagged claims internally before any warning letters or cease-and-desist demands from associations entitled to bring claims.

You can use the probability scores and severity levels displayed to prioritise findings internally. Existing evidence can then be compared with the claims concerned outside the scan. The free results page shows only a selection of the processed results.

If you adjust claims, a further scan can provide indications of the new status. The probability scores and severity levels shown are not legal verdicts but form an initial working basis. Whether a claim can stand depends on the individual case and the evidence available. As the free scan shows only a selection, passages that are not displayed are not automatically free of risk. For a final assessment, we recommend seeking advice from a lawyer specialising in unfair competition law.

Why do I need the findings from the EmpCo Scanner?

How do I proceed after the EmpCo scan?

After the EmpCo scan, first review the findings displayed with the highest probability scores. For each claim, clarify whether reliable evidence such as certificates, studies or production data is available. If a claim is substantiated, it can be assessed internally and, where necessary, legally. If no sufficient evidence is apparent on the scanned page, the finding can prompt an internal revision and a legal assessment by a lawyer.

Use the findings as a working basis to plan the necessary editorial steps. A new scan after the correction can provide indications of the new status. In this way, a repeated check can support your internal documentation.

While the EmpCo Scanner supports you in regularly checking your website, responsibility for the final assessment remains with your company. You should clarify individual legal questions with a lawyer specialising in unfair competition law. The results of the scan do not claim to be complete.