If You Claim It, Can You Prove It? Germany’s Anti-Greenwashing Law Signals a New Era for Fashion - and Why Origin + DPP Now Matter
On 30 January 2026, Germany’s Bundesrat approved sweeping anti-greenwashing legislation that will fundamentally change how companies communicate environmental claims. As reported by Apparel Insider and other industryobservers, the law amends Germany’s Act Against Unfair Competition (Gesetz gegen den unlauteren Wettbewerb, “UWG”) to implement the EU’s Empowering Consumers for the Green Transition (“ECGT”) Directive—placing fashion and textiles squarely in the regulatory firing line.
At its core, the legislation forces brands to confront a simple but increasingly unavoidable question: if you claim it, can you prove it?
A narrowing runway to compliance
The Empowering Consumers for the Green Transition (ECGT) Directive establishes two immovable deadlines. By 27 March 2026, EU member states must transpose the directive into national law. By 27 September 2026, the rules become enforceable across Germany and the EU. While this may appear to offer a transition period, fashion brands face practical constraints: packaging, hangtags, private labels, and long-term marketing campaigns often have lead times of 12 to 18 months.
Germany is among the first countries to complete national implementation, but others are expected to follow rapidly. For brands operating across multiple EU markets, this signals the need for harmonised, defensible claims—rather than fragmented, country-by-country approaches.
What the law actually changes
The amended Act Against Unfair Competition (UWG) introduces explicit prohibitions that directly challenge long-standing sustainability practices in fashion.
Generic environmental claims—terms such as “eco-friendly,” “green,” “natural,” or “biodegradable”—will be prohibited unless a company can demonstrate excellent environmental performance using recognised, credible schemes. Similarly, “climate neutral” or “CO₂ neutral” claims based solely on carbon offsetting will no longer be permitted.
Sustainability labels must now be rooted in official certification systems or government-established schemes, placing many proprietary or self-certified labels at risk after September 2026. In addition, future-oriented claims, such as net-zero commitments, must be supported by realistic, publicly available, and externally verifiable implementation plans.
Collectively, these measures shift sustainability from a narrative exercise to a substantiation requirement.
Enforcement is already accelerating
Despite the separate Green Claims Directive being halted in mid-2025, enforcement pressure has not eased. German regulators, including BaFin, have already imposed penalties for greenwashing in the financial sector. At the same time, consumer NGOs and competitors are increasingly using unfair-competition law to challenge sustainability claims across retail and fashion.
The implication is clear: the absence of pre-approval requirements does not equate to reduced risk. Claims can be challenged after they reach market, placing the burden of proof squarely on brands.
Why fashion is uniquely exposed
Fashion supply chains are long, global, and complex. Fibres are blended, materials are reprocessed, and origin information is often diluted or lost as products move downstream. While digital traceability systems and certifications remain important, regulators are increasingly asking whether the physical product itself supports the claims being made.
This disconnect—between documentation and material reality—is where many sustainability strategies begin to fracture. Documentation without physical verification struggles under scrutiny; physical testing without supply-chain context lacks operational relevance. Germany’s law underscores a broader shift: sustainability is no longer primarily about storytelling. It is a compliance function grounded in evidence.
Known fibres, yarns, recycled materials—and the role of physical verification
One of the most persistent challenges in fashion traceability is that origin and recycled-content claims are often made after material integrity has already been obscured. Even when brands work with known fibre types, nominated spinners, approved yarn suppliers, or certified recyclers, risk does not disappear. It is frequently introduced upstream through aggregation, blending, substitution, or processing losses—particularly at spinning, recycling, and early transformation stages.
Under the revised UWG, regulators are increasingly focused on whether the material characteristics of the fibre itself support the claim being made. Intention, supplier nomination, or contractual sourcing commitments are no longer sufficient on their own.
Isotope testing provides a valuable complementary layer of evidence for origin claims. By analysing naturally occurring environmental signatures embedded in fibres as they grow—reflecting climate, water sources, and soil composition—it enables an independent assessment of whether a fibre is consistent with a claimed geographic origin, without relying solely on documentation.
Used alongside known fibres and yarns, isotope testing allows brands to validate upstream assumptions, confirm whether nominated materials align with origin claims, and identify risk before products reach market.
As Kelly Thompson, Matri World, explains: “Even when brands work with trusted fibres and nominated yarn suppliers, origin risk doesn’t disappear—it just becomes less visible. Isotope testing helps ground origin claims in the physical reality of the fibre itself. Under emerging EU enforcement, that independent layer of evidence can be critical in demonstrating
that a claim isn’t just well-intentioned, but materially accurate.”
Recycled-content claims face similar—and in some cases heightened—scrutiny. As Germany moves to enforce stricter substantiation requirements, brands must
demonstrate not only that recycled materials were sourced, but that recycled content is securely preserved and verified across every transformation step.
This has increased attention on German-based traceability technology providers, such as Tailorlux, that embed verification directly into recycled material flows—
providing tamper-resistant, material-level evidence that can withstand regulatory review.
As Tobias Herzog, CEO of Tailorlux Integrity Solutions, notes: “Recycled content claims only remain credible if traceability is built into the material itself and maintained across every transformation step. As regulation tightens, brands will need secure systems that can demonstrate recycled material integrity—not just once, but continuously throughout the supply chain.”
Together, fibre-origin verification and secure recycled-material traceability strengthen a brand’s ability to defend environmental claims under Germany’s evolving enforcement framework.
Connecting origin proof with Digital Product Passports
The same systems now being discussed at EU policy level—origin traceability, location granularity, and Digital Product Passports (DPPs)—are already being tested through national greenwashing enforcement. As Germany’s revised Act Against Unfair Competition demonstrates, traceability frameworks are no longer evaluated only on their transparency ambitions, but on whether they can withstand regulatory challenge. Bridging policy design and compliance reality is no longer optional; it is the difference between credible disclosure and legal exposure.
Against this regulatory backdrop, the collaboration between Kinset and GenuTrace reflects a pragmatic response to the new compliance reality.
Rather than treating sustainability claims, origin verification, recycled-material traceability, and Digital Product Passports as separate exercises, the collaboration links physical evidence—including fibre-level origin verification and secure material traceability—with digital, regulator-legible product records. DPPs provide a structured framework for communicating substantiated claims consistently across markets, while physical verification ensures the information behind those records is defensible.
As Katie O’Riordan, CEO and Co-Founder of Kinset, explains: “Regulation is moving sustainability out of marketing and into accountability. Digital Product Passports only work if the information behind them is accurate, verifiable, and genuinely linked to the physical product. Origin proof plays a key role, alongside other forms of verification, in turning sustainability claims into something brands can actually stand over.”
From sustainability storytelling to audit-ready evidence
The direction of travel is unmistakable. Even without the Green Claims Directive, the ECGT rules already prohibit the most problematic practices—generic claims, offset-only neutrality, unverifiable labels, and aspirational promises without plans.
For fashion brands, the strategic response is not louder sustainability messaging, but greater precision and restraint. Claims must be limited to what can be proven. Systems must be designed not only for consumer communication, but for regulatory challenge.
Germany’s decision sends a clear signal across Europe: sustainability claims have entered an enforcement era. In that environment, the most resilient strategies are those that replace promises with proof—and connect physical evidence to digital transparency by design.
As the industry moves toward mandatory Digital Product Passports and stricter consumer protection, one question will increasingly determine who is ready and who is exposed: if you claim it, can you prove it?
