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EmpCo and stock placed on the market before 27 September 2026 (Germany, Austria)

Last review: 5 October 2026.

Scheme owners and label holders often ask what happens to packaging already printed or goods already in shops when EmpCo national rules apply from 27 September 2026. This guide summarises verified sources for Germany and Austria only. It is not legal advice. Glint does not certify any label.

Sources checked 2026-10-01 (Germany consolidated text rechecked 2026-10-05):

Austria: goods placed on the market before 27 September 2026

Austria (fact AT1): the UWG amendment BGBl. I Nr. 58/2026 is published; the listed provisions, including Annex Z 2a, apply from 27 September 2026.

Austria (fact AT2): for three years after those provisions enter into force, civil claims concerning goods for breaches of the listed provisions can only be brought if the goods were placed on the market after 27 September 2026. The official text covers goods. A WKO note (secondary source, 17 September 2026) states that services are not covered: wko.at.

Confirm how this applies to your channels with your adviser.

Germany: no general sell-off period in promulgated law

Germany (fact DE1): the Third Act amending the UWG applies from 27 September 2026.

Germany (fact DE3): UWG Annex Nr. 2a blacklists certain sustainability labels towards consumers when the label is not based on a certification scheme or not set by public authorities.

On stock already on the market, there is no general sell-off period in the promulgated UWG text we reviewed.

Germany (fact DE4): the Bundestag adopted on 24 September 2026 a new section 15b UWG on claims under listed provisions for goods placed on the market before 27 September 2026, with a proportionality test (see BT-Drs. 21/8158). As of 5 October 2026, this section does not appear in the consolidated UWG on gesetze-im-internet.de. The legislative process may not be complete. Do not treat section 15b as promulgated national law today. To confirm with your adviser.

Other EU member states

In the in-app EmpCo transposition tracker, every country other than Germany and Austria remains not verified until Label Registry documents a reviewed official source. We do not state national stock rules for those countries here.

What Label Registry helps with

Glint publishes Label Registry. The product does not certify and does not provide legal advice.

Related guides

EmpCo deadline: 27 September 2026EmpCo national transposition (EU 27)

EmpCo transposition tracker (EU 27)

Operational aid. This page is not legal advice, and Glint does not certify.