Germany carves out limited relief for pre-EmpCo packaging stock

The EU's Empowering Consumers for the Green Transition (EmpCo) directive, tightening rules on environmental and sustainability claims on packaging, took effect in Germany on 27 September 2026. Days before the deadline the Bundestag added a new clause, Section 15b, that lets courts weigh proportionality in injunction claims against packaging already placed on the market before that date, but it stops short of a blanket amnesty for existing stock.

Why this mattersBrand owners and converters must now audit claims on unfilled warehouse stock and new production immediately, while only already-marketed goods get limited legal cover.

• EmpCo's stricter rules on green claims took effect in Germany on 27 September 2026.
• The Bundestag added Section 15b days before the deadline to address packaging produced before the cut-off.
• Section 15b can be weighed in injunction claims only for packaging already placed on the market before 27 September 2026.
• Unfilled packaging stock still in warehouses is not covered and must comply with EmpCo.
• New packaging production and online communication from 27 September 2026 must be EmpCo-compliant.
• Generic claims such as 'environmentally friendly' or 'sustainable', and unaccredited sustainability seals, are now restricted.

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