EmpCo Audit for Online Shops: the EmpCo Check for Every Green Claim
We systematically check your shop or website for green claims: copy, product images, seals and filters. You get a roadmap prioritised by impact, with task packages per team and data source.
Since 27 September 2026 the new German UWG rules on environmental claims apply. Websites and shops must comply immediately, with no transition period.
Scope
What we check in your shop
- Category banner
- Filters
- Image gallery with label
- Product title
- Badge
- Product copy
Green claims hide in more places than most shops expect. We check every area where environmental statements appear:
- Product images with packaging claims, badges and manufacturer seals
- Product and series names containing terms like “eco”, “organic” or “green”
- Product copy with statements like “environmentally friendly”, “sustainable” or “made from recycled material”
- “Climate neutral” via offsetting on product pages and in campaigns
- Self-created and fantasy seals without a certification system
- Filters and categories such as “sustainable products”
- Category and SEO copy with your own environmental claims
- Brand pages about sustainability
EmpCo check or full audit? The EmpCo check covers a sample or selected areas and projects the results across the entire shop. The full EmpCo audit captures every page and template on the website, optionally including channels you provide: newsletters, service emails, customer accounts, ads and marketplace listings. In addition to environmental claims the review covers durability and repairability statements as well as forward-looking claims without an implementation plan.
The new UWG rules explicitly cover images, graphics and symbols (§ 2 (2) no. 5 UWG). Retailers are liable for manufacturer claims they display in their own shop under prevailing legal opinion (German Federal Court of Justice, I ZR 86/13). Your own filters and categorisations count as your own claims.
How we classify every finding
Every finding gets a classification. The legal basis is the per-se prohibitions in the UWG annex (the “black list”) and the general prohibition of misleading practices.
| Classification | Meaning | Example claim | Action required |
|---|---|---|---|
| Red | Per se unlawful, no case-by-case assessment | “climate neutral” based on offsetting | Remove or reword |
| Yellow | Lawful if specific and substantiated | “made from 70% recycled plastic” | Provide evidence or make more specific |
| Grey | No environmental reference or uncritical | “vegan formula” | Documented, no action needed |
| Legal question | Interpretation unclear, legal review needed | Filter “sustainable products” with own criteria | Refer to your legal team or law firm |
Every classification comes with the rule applied, the legal basis and a suggested correction.
How the audit works in five steps
- Define scope. Together we decide whether to start with an EmpCo check (sample with projection) or the full audit, and determine areas, page types and markets.
- Capture the shop. We extract copy and original images for each page area: product pages, categories, brand pages, banners, filters, templates. Packaging text, seals and badges on product images are included.
- Review claims. An AI-assisted analysis checks every claim against a review catalogue based on the UWG and EU Commission guidance, with fixed rules for known edge cases. A second AI review verifies findings against written review guidelines. We measure hit rates on a sample.
- Decide once. We group identical claims into categories (e.g. “climate neutral via offsetting”, “self-created seal”). For each category we prepare a recommendation with the legal basis and walk you through it. You decide once per category. Open legal questions go to your law firm.
- Fix and repeat. You receive task packages per category, brand and data source, prioritised by impact. When new products or manufacturer updates arrive, we repeat the check as a delta review.
Sample finding from a fictitious shop
Sample finding (fictitious shop). This is what a finding looks like in the audit. Brands and products are invented.
| Claim (quote) | Location | Classification | Reason | Suggested correction |
|---|---|---|---|---|
| “climate neutral” | Product page › Image gallery › Image 3 of 7 (packaging) | Red | Per-se prohibition no. 4c: climate neutrality based on offsetting | Replace image with compliant packaging shot, notify manufacturer |
| “eco-friendly packaging” | Product name | Red | Per-se prohibition no. 4a: general environmental claim without proven outstanding environmental performance | Replace with a specific benefit (e.g. “packaging made from 80% recycled paper”) or remove |
| “Green Choice” (self-created seal) | Product page › Image gallery › Badge | Red | Per-se prohibition no. 2a: seal without certification system | Remove badge or switch to a recognised seal |
| “made from 70% recycled plastic” | Product copy, paragraph 2 | Yellow | Specific, verifiable claim: lawful if substantiated | Request and file evidence from the manufacturer |
| “Sustainable products” | Category filter | Legal question | Own categorisation without published selection criteria | Define and publish criteria, have a lawyer review |
| “vegan” | Product copy, paragraph 1 | Grey | Product property without environmental valuation | Documented, no action needed |
In the real audit every row also includes a link to the original source, the legal basis, required evidence and the data source (PIM, manufacturer image data, CMS, shop system or campaign).
What you get
- Finding list with location and link. Every claim with a verbatim quote, exact location (e.g. “Product page › Image gallery › Image 3 of 7”) and a direct link.
- Claim categories with recommendation. Identical claims grouped; each category with the legal position and the condition for compliance. Decide once, the decision applies to all findings of that type.
- Task packages per category, brand and data source. Who needs to act: PIM, manufacturer image data, CMS, campaigns or shop system.
- Roadmap prioritised by impact. A single template change before a hundred individual edits.
- Projection for the entire shop when working from a sample, with confidence range and effort estimate.
- Legal questions prepared for your law firm.
- Delta check for new products, repeatable on request.
Our role in the EmpCo audit
Buzzmatic is an agency with deep experience in e-commerce and data processing. In the EmpCo audit we deliver a complete, documented inventory of every green claim in your shop, with classification and suggested corrections. The legal assessment of each claim category is made by your legal department or law firm. We prepare the open legal questions for them and are happy to work with them directly. Buzzmatic does not provide legal advice within the meaning of the German Legal Services Act (Rechtsdienstleistungsgesetz).
Clients
We work with shops and brands in e-commerce
Your contact
Raoul Schreck
CEO & Co-Founder
Raoul has been doing SEO for over 15 years, with positions at Pixum, Groupon and Fashion For Home. He co-founded the agency in 2010 and is your contact for the EmpCo audit.
LinkedInFrequently asked questions about the EmpCo audit
The rules cover any business that makes environmental claims to consumers: online shops, brand and manufacturer websites, D2C shops, corporate websites with sustainability pages and service providers with environmental references in their communications. Retailers are also liable for claims that originate from the manufacturer.
The new German UWG rules contain per-se prohibitions that apply without case-by-case assessment: sustainability seals without a certification system (no. 2a), general terms like “environmentally friendly” without proven outstanding environmental performance (no. 4a), environmental claims about the entire product that only relate to one aspect (no. 4b), and “climate neutral” based on offsetting (no. 4c). The general prohibition of misleading practices also applies: specific claims such as “made from 50% recyclate” are lawful if true and substantiated.
Yes. If you sell under your own name and display the manufacturer's text, images and seals in your shop, this is considered your own commercial practice under prevailing legal opinion (German Federal Court of Justice, I ZR 86/13 “Himalaya Salt”). Your own filters and categorisations such as “sustainable products” count as your own claims. For private-label products the retailer is also the manufacturer.
The new UWG rules have been applicable since 27 September 2026. There is no transition period for websites, shops and advertising.
The Green Claims Directive (GCD) is a 2023 EU proposal that has been blocked since June 2025. There is no pre-certification or verification body from the GCD. The current benchmark is the EmpCo rules transposed into German law via the UWG, plus the advertiser's burden of proof.
No. The audit delivers a complete, documented inventory of all green claims in your shop, with classification and suggested corrections. The legal assessment of each claim category is made by your legal department or law firm. We prepare open legal questions so your law firm can work with them directly.
After the initial audit we recommend a delta check whenever new products, manufacturer updates or campaigns go live. New articles and changed manufacturer copy bring new claims into the shop. How often this is needed depends on your assortment size and rate of change.
Yes. The UWG rules apply to environmental claims across the entire commercial process, including brand, manufacturer and corporate websites. We check sustainability pages, product presentations and campaign landing pages, on request also newsletters, ads and social media posts.
Get started
Start with an EmpCo check
You can start with a random sample and project the results across the entire shop. We clarify scope and approach in a first conversation.
Talk to Raoul about your EmpCo check
HQ Berlin // Schönhauser Allee 149
Talk to Raoul about your EmpCo check
In a first conversation we clarify the scope and show you what a finding would look like for your shop.