Are own sustainability logos still allowed?

No, unless the logo is based on a certification scheme or was established by public authorities. Since 27 September 2026 this sits on the blacklist of the German Unfair Competition Act, number 2a, and applies towards consumers in all circumstances. The underlying claim may well be factually correct; displaying the mark is prohibited nonetheless.

What counts as a certification scheme

A certification scheme must make its conditions, including the requirements, publicly available and meet four criteria:

• Open to all. The scheme is open to all traders willing and able to comply, on transparent, fair and non-discriminatory terms.
• Developed with experts. The requirements are drawn up in consultation with relevant experts and stakeholders.
• Sanctions and withdrawal. There are procedures for dealing with non-compliance and the possibility of withdrawing or suspending use of the label.
• Independent monitoring. Compliance is monitored under an objective procedure by a third party whose competence and independence are assured.

An in-house standard generally fails this: it is not open to other companies, and it is not monitored by an independent third party. A label whose compliance the company checks itself already fails the fourth criterion.

What this means for retailer own brands

This is not only about small house marks. Retail chains run their own sustainability marks on their own brands, setting the criteria themselves and checking compliance themselves. Towards consumers that is no longer permissible from the application date unless an independent scheme sits behind it. On top of that, the retailer is the brand owner of its own brands and therefore the party displaying the mark. The duty to check lies with the company displaying the label, not with the label owner. Anyone using a third-party label that does not meet the requirements is liable as well; an assurance from the label owner is not enough.

What happens to existing logos

Existing own labels have to be adapted by the application date or may no longer be used towards consumers after it. For goods already produced or distributed before then, the Commission services name practical routes: covering the mark, correcting the claim or adding supplementary information at the point of sale.

The grey area next to it

Not every graphic element is a label. A green leaf, a globe or an all-green design is not a sustainability label within number 2a, but it can amount to a generic environmental claim under number 4a where it creates the impression of environmental performance. The line is drawn by the overall impression. The free claim check looks at up to five claims and marks.