Local Guide · Germany
ECGT Compliance in Germany: What Fashion Brands Need to Know
German transposition of EU Directive 2024/825 — deadlines, authorities, fines, and why Germany enforces more strictly than France or Spain.
Last updated: June 2026
When does what apply in Germany?
March 2024
EU adopts ECGT Directive 2024/825
The Directive enters into force on 26 March 2024.
March 2026
Germany transposition deadline
The German legislature must transpose the Directive into national law by 27 March 2026 (primarily via the UWG).
September 2026
Enforcement begins in Germany
From this date, active monitoring and prosecution by market surveillance authorities commences.
Ongoing
Regulatory checks
Regular reviews — particularly in the fashion industry, which is classified as a high-risk sector.
Who enforces in Germany?
State Market Surveillance Authorities
Primary enforcement authority
Each federal state has its own market surveillance authorities (e.g. Regional Councils, Trade Supervision Offices). They conduct product checks and website audits.
Federal Cartel Office
Competition law cases
For dominant companies or systemic violations, the Federal Cartel Office may intervene — particularly for competition-distorting greenwashing practices.
Wettbewerbszentrale / IDO
Competitor cease-and-desist notices
Competitors and associations can independently issue notices and file injunctions — without waiting for authorities. This is particularly active in Germany.
LKA / Customs
On product import
For physical products with misleading greenwashing labels, customs authorities and state criminal investigation offices may also act.
What is the UWG — and how does it relate to ECGT?
Unfair Competition Act (UWG) is Germany's central instrument against misleading advertising. Sections 5 and 5a UWG already prohibit misleading business practices — including unsubstantiated environmental claims.
The ECGT transposition will supplement the UWG with a new Annex I that explicitly lists the EU's prohibited practices (Annex I, 4a–4d). This means: authorities and claimants no longer need to argue in general terms — they simply point to the list. This significantly increases the enforcement risk.
Fines in Germany — in detail
| Violation Type | Legal Basis | Sanction |
|---|---|---|
| Generic environmental claim without proof | UWG § 5 + ECGT Annex I, 4a | Injunction + up to 4% revenue |
| Carbon neutrality claim via offset | UWG § 5 + ECGT Annex I, 4c | Warning, fine up to €40,000 (startup) or 4% |
| Misleading comparison | UWG § 5a + UCPD Art. 7 | Injunction, damages possible |
| Future promise without milestone plan | UWG § 5 + UCPD Art. 6 | Warning + fine on repetition |
| Repeated violation | UWG + regulatory order | Enforcement fine up to €250,000 possible |
What is different from France / Spain?
| Aspect | Germany | France | Spain |
|---|---|---|---|
| Enforcement rigour | Very strict — Germany has a strong cease-and-desist culture under competition law. | Moderate — AGEC (plastic) already strict, greenwashing still developing. | Less active — CNMC not yet specialised in greenwashing. |
| Cease-and-desist culture | Highly active — competitors and associations sue independently. | Low — authorities act primarily; few private lawsuits. | Low — consumer authorities dominate. |
| National supplementary laws | UWG § 5, § 5a (misleading), UWG reform expected from 2026. | Loi Climat et Résilience (2021) + AGEC already in force. | Ley de residuos — less focused on claims. |
| Responsible federal authority | Decentralised: state authorities + Federal Cartel Office. | Centralised: DGCCRF (Direction Générale de la Concurrence). | CNMC at national level. |
Conclusion: Germany has one of the most active cease-and-desist cultures in the EU. While in other countries primarily authorities act, here competitors and associations can sue independently and quickly — often before regulatory enforcement begins.
Frequently Asked Questions
Do small German online shops also need to comply with ECGT?
Yes. The Directive applies to all traders selling products or services to consumers in the EU — regardless of company size or location.
Does ECGT also apply to Amazon Marketplace sellers?
Yes. Marketplace product descriptions on Amazon.de, Zalando, or other platforms are also subject to ECGT. Platform operators are not automatically liable; the seller remains responsible.
What is the difference between ECGT and the existing UWG?
The UWG (Unfair Competition Act) already applies today. The ECGT transposition will supplement the UWG with specific prohibitions from Annex I and clearer definitions of what constitutes 'misleading'.
Who has already initiated green claims proceedings in Germany?
Before ECGT, organisations including Deutsche Umwelthilfe (DUH) and the Wettbewerbszentrale have initiated proceedings against companies for misleading sustainability advertising (e.g. Katjes – Federal Court of Justice ruling 2024, dm-drogerie markt, Lidl).
Do I need to register with the German Institute for Standardisation (DIN) or the Federal Environment Agency?
No. ECGT does not require active registration. However, you must ensure that every environmental claim is backed by a recognised certificate verified by an accreditation body.
Further Reading
Compliance for the German market
Book a demo and learn how TrueGoods protects you from cease-and-desist notices and fines.
Book a demo