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“Ohne GenTechnik” seal complies with new EU regulations on consumer protection
Photo: Concept Photography Berlin
On 27 March 2024, the “Directive on empowering consumers for the green transition” (EmpCo Directive, EU 2024/825) came into force. This expanded the Unfair Commercial Practices Directive (UCP Directive) to include the aspect of “greenwashing”. As a result, unclear or vague advertising claims in particular will be subject to stricter scrutiny.
In addition, objective requirements are imposed on the use of environmental quality labels, known as “sustainability labels”. Among other things, it is prohibited to affix a sustainability label that is not based on a certification system or has not been established by government agencies. The directive must be implemented by the EU Member States within 24 months; in Germany, a government draft is now available.
The Berlin-based law firm Hildebrandt, on behalf of the Association Food without Genetic Engineering (VLOG), has investigated the impact of the new regulations on the “Ohne GenTechnik” seal. According to the expert opinion, the seal “most likely” falls within the scope of the directive, as it is a sustainability seal.
The “requirements for permissible use of the seal in commercial transactions” are also “highly likely to be met,” according to the expert opinion, because “the labelling system is based on a certification system that complies with the requirements of the EmpCo Directive and the expected national implementation law.” Further regulation of the use of the “Ohne GenTechnik” seal is not to be expected, as it does not make any so-called “general environmental claims” within the scope of the new directive.
"VLOG welcomes the new protection against misleading greenwashing advertising. It comes as no surprise that the ‘Ohne GenTechnik’ seal, with its comprehensive regulations and established independent certification system, can continue to exist under the new regulations, but it is a nice further confirmation and distinction for us. Food manufacturers and retailers can continue to convince their customers of the GMO-free quality of their products with our seal," says VLOG Managing Director Alexander Hissting.
The Empowering Consumers Directive is to be supplemented and specified in future by a further so-called “Green Claims” directive, but the current draft was initially withdrawn in July 2025. VLOG is keeping an eye on the issue and its impact on the “Ohne GenTechnik” seal.