Whether the EmpCo Directive also covers employer seals is still an open legal question. The directive, (EU) 2024/825, is aimed at greenwashing. In Germany it was implemented through the third amendment to the Act against Unfair Competition (UWG), which has fully applied since 27 September 2026. Sustainability labels that are not based on a transparent certification scheme are now prohibited.

For employer seals, experts discuss “social washing”, meaning unproven claims about fair working conditions or a good company culture. The Praxisleitfaden Mitarbeitergewinnung therefore recommends a precautionary approach: an anonymous survey of the whole workforce, external third-party verification and a transparent catalog of criteria. This is general information, not legal advice; for a specific case, consult a lawyer specializing in competition law.