Austria's greenwashing law, set to come into effect in September 2026, isn't just a matter for European companies. If you ship goods to Austria or the EU market and your boxes, labels, or website have the words "Eco-friendly," "Sustainable," "Green," or "Carbon Neutral" anywhere, you need to read about this before your next shipment leaves the warehouse.

The worrying aspect isn't that the law is complex or difficult to understand, but that many Thai SMEs are unaware that they are affected because these terms are often included on packaging during the design phase, without considering the day when they'll need to prove their accuracy.

What is Austrian money laundering law and when did it begin?

Austria is amending its law on unfair competition, known as UWG-Novelle 2026, which is expected to pass parliament in July 2026 and come into effect from September 27, 2026. This law is part of the EU's EmpCo framework, which aims to protect consumers from exaggerated or unsubstantiated environmental advertising.

The significance of this legislation is that Austria was one of the first EU countries to legally implement the EmpCo framework. This means that other EU countries will gradually follow suit. If you plan to sell in Europe long-term, this is a signal to start adapting now, not to wait until the law comes into effect to make changes.

Three main prohibitions that directly affect Thai SMEs.

This law prohibits three behaviors that many Thai SMEs unknowingly engage in. The first is using unsubstantiated environmental claims such as “Eco-friendly,” “Green,” and “Sustainable” on packaging without independent certification or scientific evidence. If you use these terms, you must be able to prove their validity.

The second point is that claiming an entire product is sustainable when sustainability only comes from a small component, such as recyclable outer packaging, while the core manufacturing process or internal materials still have an environmental impact, is also illegal.

The third point is the claim of "Carbon Neutral" or "Net Zero" products by purchasing carbon credits to offset emissions, instead of actually reducing greenhouse gas emissions during the production process. This law considers simply purchasing carbon credits insufficient and constitutes self-greenwashing.

The penalties for violating the rule are not just a warning.

Many might think that a first offense would only result in a warning, but this law doesn't work that way. Companies that violate the law can be fined up to 4% of their total annual revenue, which is a significant figure for SMEs with existing sales in Europe.

Even more worrying is that it's not just government agencies that can sue. Trade competitors and consumer protection associations can also immediately request a sales halt, even for a first offense. This means that if your competitors in the Austrian market find that your label contains unsubstantiated claims, they have the right to take legal action.

There are some exceptions for goods already on the market before September 27, 2026, which will receive a three-year civil grace period. However, this applies to goods already on the market, not to goods you will ship after the law comes into effect.

Austrian money laundering laws: Checklist to check before actually sending the goods.

Before the next shipment goes to Austria or the EU market, you should go through this list one by one. Don't skip even one, because each point is something that could lead to complaints or a suspension of sales.

• Labels and packaging: Scan every term related to the environment, such as Eco, Green, Sustainable, Natural, Bio, Carbon Neutral. If these words are present, they must be supported by evidence or replaced with more specific and measurable language.
• Certification from an independent agency: If you claim your product is recyclable or environmentally friendly, it must have certification from a recognized organization such as TÜV, FSC, Ecolabel EU, or equivalent, not just a logo designed by your company.
• Website content and e-commerce: Review all product pages, descriptions, and banners used in the European market. Online claims are also subject to this law.
• Advertising media and product inserts: Leaflets, catalogs, and documents included in the packages shipped with the goods must undergo the same inspection as the main label.
• Claims of Carbon Neutral or Net Zero: If you use these terms in any communication, there must be a genuine emissions reduction plan, a timeframe, and a verifiable verification mechanism. Simply buying carbon credits is no longer sufficient.
• Supply chain: If you claim an entire product is sustainable, that must be verifiable throughout the entire supply chain, not just the visible parts.
• Custom-designed environmental logo: Logos or symbols created by a company without external certification may be perceived as greenwashing. They should be replaced with verifiable standard references.

Impact on costs and planning time.

Label and packaging updates aren't something that can be done overnight. If you need to redesign labels, obtain certifications from independent agencies, and reprint packaging, this process can take 3-6 months or more, depending on the type of product and the certification agency you choose.

The cost of obtaining environmental certifications from independent organizations in Europe varies greatly. Some standards can cost tens of thousands of baht, while others can reach hundreds of thousands of baht per year, depending on the type of product and the scope of certification. This cost must be included in the landed cost of goods shipped to Europe.

If you ship multiple product models or SKUs to the European market, prioritize which SKUs have the most risky environmental claims and start adjusting those first. Don't wait until all SKUs are affected to do it all at once, as there isn't much time left before September 2026.

Questions that European buyers might ask you after the law comes into effect.

If your buyer in Austria or the EU starts asking about this, you need to be able to answer clearly, not just by saying "We use recycled materials." You need to state the percentage of recycled materials, their source, the certifications available, and how they can be verified.

Questions buyers often ask in markets with such regulations include: "Is there certification from an independent agency?", "Is there a Life Cycle Assessment (LCA) for the product?", "If claiming carbon neutrality, is there a verifiable emission reduction plan?", and "Has the submitted label been reviewed according to EmpCo standards?" If you can't answer these questions, you should start preparing the information now.

Some buyers may request additional documentation before issuing a new Purchase Order, or they may ask you to send a sample of a new label for review beforehand. This can delay the ordering process if you haven't prepared these documents in advance.

Customs and inspection risks at the destination.

Although this law doesn't directly change customs procedures, if your goods are subject to a complaint after being placed on the Austrian market, the subsequent process could affect subsequent export batches, as the buyer might temporarily suspend orders while the complaint is being investigated.

In some cases, if the sale of goods is suspended by a court order or regulatory agency, the goods in the buyer's warehouse or in transit may not be able to be sold normally, which may lead to complex negotiations regarding returns or compensation.

Therefore, checking labels and documents before shipping each batch is not only to prevent legal issues, but also to reduce the risk of affecting long-term relationships with buyers.

What types of Thai products should we be particularly cautious about?

The products most likely to be affected are those that frequently use environmental claims in their marketing, including organic and natural foods, cosmetics and skincare products that claim to be natural or organic, packaging that claims to be recyclable or biodegradable, wood products or natural materials that claim to be from sustainable sources, and fashion or textile products that use the terms "eco-fashion" or "sustainable fashion."

If your product falls into these categories and you are already exporting to Europe, or are planning to expand into Europe, you should start reviewing all claims being used in that market as soon as possible.

How to make a claim legally valid without damaging your positioning.

Complying with legal claims doesn't mean you have to remove everything related to the environment, but rather shifting from vague statements to specific, verifiable data.

For example, instead of writing “eco-friendly packaging,” change it to “Packaging made from 70% recycled PET plastic, certified by [organization name].” Instead of writing “sustainably produced,” change it to “Produced using 80% solar power in the manufacturing process, data as of 2025.” Making these changes not only improves legal compliance but also increases the perceived credibility of the message in the eyes of a knowledgeable buyer.

If you don't yet have enough specific information to use as a replacement, the safest option is to remove the claim first and then add it back when you have supporting evidence.

The direction the EU is heading, and what to watch out for next.

Austria is not the only EU country moving forward with this. The EU's EmpCo framework is designed for implementation by all member states, meaning that Germany, France, the Netherlands, and other EU countries will gradually enact similar legislation during 2026-2027.

In addition, the EU has a Green Claims Directive currently undergoing EU legislation, which will set common standards for environmental claims across the EU. Once this law comes into effect, exporters who have not yet adapted will face pressure from multiple directions simultaneously.

Key issues to watch over the next 6-12 months include the progress of the Green Claims Directive at the EU level, the actual enforcement of Austrian law after September 2026, and changes in requirements from major EU buyers who may begin requesting additional documentation even before the law officially comes into effect.

Things to do in the next 3 months.

If you are already shipping goods to Austria or the EU, or are planning to start, the best thing to do now is to audit all environmental claims used in the European market, including those on labels, websites, catalogs, and advertising materials.

Next, identify which claims have readily available supporting evidence, which require further certification, and which should be removed or replaced with more specific wording. If new certification is needed, begin the process immediately, as it can take several months.

For more information on preparing export documents and planning international shipping, you can refer to the following reference materials. smeshipping.com

The most important thing is not to wait until September 2026 to start inspecting, because if it's found that you need to change labels or obtain new certifications, you won't have enough time to complete it before the law comes into effect, and products shipped after that will immediately be at risk.

Austrian money laundering laws: Double-check before negotiating prices and before closing a container shipment.

Before submitting a quote to a buyer in Austria, you should clearly separate the cost of the goods, packing costs, shipping costs, insurance, documentation fees, and destination charges. If you combine everything into a single lump sum, you won't know where your profit goes when shipping costs change.

For consumer goods and packaging claims, the first step before submitting a price quote is to obtain complete destination information from the buyer. This includes the preferred port, Incoterms terms, desired delivery date, payment method, and customs documentation. This information helps you assess the risk before accepting the order.

If a buyer requests a price quote, you should check it carefully. Avoid giving a broad, approximate price; instead, provide a price range, specify the quotation's expiration date, and mention that freight surcharges or other additional costs may vary depending on the shipping booking date. This helps prevent disputes when the goods are ready for shipment.

Documentation issues should be checked from the beginning, not waiting until production is complete to inquire. Some documents require time to obtain from relevant agencies or labs. Missing documents on delivery day can result in costs beyond just penalties, including delays and decreased buyer trust.

Key points to discuss with your freight forwarder include: checking packaging artwork, product inserts, e-commerce copy, and market-specific labels before shipment to Austria; and preparing supporting evidence for any environmental or net-zero claims. Ask about standard transit times, alternative routes in case of risk, costs not included in the freight quote, and insurance claim conditions in case of damage or delays.

Another point to be aware of is that unsupported or vague green claims may trigger fines, sales suspensions, and complaints from competitors or authorities; details of product-by-product enforcement are unknown from the article. This might not be visible in the initial quotation but could surface during buyer document review or when customs at the destination request additional information. Preparing this information in advance can therefore help speed up the deal.

• Separate the cost of goods, shipping, insurance, and documentation onto different lines before submitting a price quote.
• Clearly confirm the Incoterms with the buyer, specifying who is responsible for the final delivery costs.
• Verify that the HS Code and product name in the invoice match the packing list and shipping documents.
• Please provide a freight quote that includes all applicable surcharges, not just the base freight price.
• Specify the expiration date of the quotation to mitigate the risk of fluctuating freight rates.
• Keep product certification documents and product photos ready to respond to buyers immediately.
• Start with a sample shipment if you haven't shipped to this market before, to reduce risk before placing a large order.

If you use this checklist before starting pricing discussions, your first export transaction won't be guesswork, but rather a decision based on actual costs, real documentation, and real risks. This will help you negotiate with the buyer with more confidence.

Austrian green laundering law: Documents, standards, and evidence that the buyer should receive.

For consumer goods and packaging claims entering Austria, you should separate product documents from shipping documents from the outset. Product documents may include specifications, ingredient lists, certificates, test reports, and labels. Shipping documents should be checked to ensure that the invoice, packing list, bill of lading, and originating documents match in terms of product name and quantity.

If a product requires lab testing, don't wait until production is complete to send samples. Ask the buyer beforehand what standards are required, which labs are reputable, and how long the test results are valid. This helps reduce duplicate testing and allows for more realistic delivery dates.

Labels and packaging should be reviewed from the artwork before actual printing. The buyer should confirm the product name, ingredients, weight, country of origin, production date, expiration date, and any warning messages required by the target market. Revising the artwork is also cheaper than modifying a finished product.

It's advisable to keep a complete set of evidence for each lot, including product photos, labels, outer boxes, batch numbers, and quality control documents. When the buyer or customs ask, you'll be able to answer with a single set of information, avoiding the need to search multiple parties during rush orders.

• Please provide a written checklist of documents from both the buyer and the customs broker.
• Confirm that the product name, HS Code, and details in the invoice are consistent.
• Check that the certificate and test report are valid for the specified dates and cover the import period.
• The buyer must approve the label artwork before ordering the actual packaging production.
• Link the lot number to the packing list and include photos of the product before sealing the box.
• Allow time for document revisions and requests for additional information from the recipient.

Austrian money laundering laws: Signals to watch out for after submitting a sample.

After sending samples to Austria, don't just focus on whether the buyer likes the product. You should also ask: what price would allow them to resell? What packaging size is suitable for this distribution channel? And what documents are causing the purchasing team to spend a long time reviewing them? Answering these questions will help you adjust your product and costs before accepting large orders.

You should record the time taken for each step, from preparing samples and obtaining documents to booking transportation, clearing customs, and finally receiving the goods from the buyer. If any step takes longer than expected, you'll know whether to allow extra time or change the shipping method for the next time.

When raw material prices, exchange rates, or freight costs change, review your landed cost. Do not automatically use prices from previous shipments, as seemingly sufficient margins may be lost due to surcharges, storage, inspection, or destination documentation correction fees.

A review date should be scheduled jointly with the sales, production, and export departments after the buyer receives the sample. This ensures that all information is consistent across all departments, including quality, price, packaging, documentation, and shipping time. If each department keeps separate data, subsequent revisions will be delayed, and responses to the buyer may be inconsistent.

For the first order, it's advisable to set conditions for increasing the quantity in advance, such as the product damage rate, customs clearance time, the number of document revisions, and the margin after including actual costs. Once the data meets the criteria, then increase the quantity. This approach ensures evidence-based growth, not just expectations.

• Ask the buyer about the trial sales figures and any actual complaints received.
• Review the lead time from production to the final delivery date.
• Compare the actual costs with the quotation item by item.
• Record the questions from the customs broker to prepare for the next document preparation round.
• Determine a decision point to expand the order, adjust the product, or stop the trial.
• Assign a data owner for each set of data so that the same data can be used to respond to buyers.
• Track actual costs incurred for storage, inspection, and document corrections.
• Review the results after each shipment before confirming the price and quantity for the next order.
• Keep records of your decisions and results for comparison with the next shipment.

A short summary is compiled after each shipment, detailing what passed, what needs fixing, the person responsible, and the date for a follow-up inspection. This allows the team to immediately utilize past lessons learned and avoids starting the analysis from scratch with every new order.

Source: Department of International Trade Promotion (DITP), Trade Promotion Office in Vienna, June 2026.

Austrian money laundering laws: Check the conditions before deciding.

Austrian green laundering laws should begin with a thorough review of documents, costs, and end-user conditions before confirming a price. This approach helps reduce risk and allows for planning based on factual information.

For more official information, please check: Related sources of information