What evidence does an environmental claim on packaging need from September 2026?

Three things: a specific, measurable claim, evidence that covers exactly that claim, and the possibility to verify both from the outside. From 27 September 2026 this follows from German unfair competition law, which implements the EmpCo Directive.

What works as evidence

• A test report from an accredited laboratory to ISO/IEC 17025: confirms a measurement on the sample submitted.
• Certification against a published programme, assessed by a body to ISO/IEC 17065: additionally assesses conformity, monitors it over time and governs which claim may be made.
• Public verifiability, for example through a licence number in a certification database.

What is not enough

A supplier declaration is the starting point of the assessment, not its result. Responsibility stays with whoever makes the claim towards consumers. A test report on its own covers the sample submitted, not ongoing production. And evidence that measures something other than what the claim asserts does not carry it: anyone advertising recycled content needs evidence about recycled content, not about recyclability.

Where the evidence has to sit

The specification belongs clearly and prominently on the same medium as the claim itself. A QR code or an asterisk does not suffice. For packaging, the underlying evidence additionally belongs in the technical documentation under Annex VII of the PPWR.

The practical route

Collect every claim on packaging, website and in advertising, put the source next to each one, close the gaps or drop the claim. Whether a wording holds up is assessed by the free claim check for up to five claims, with a written assessment as a PDF.

Version: September 2026