Federation of German Consumer Organisations v. FIFA

The Verbraucherzentrale Bundesverband (VZBV), the umbrella body of German consumer organizations, brought an action against the Fédération Internationale de Football Association (FIFA) before the Landgericht Berlin II, challenging environmental advertising claims FIFA had made on its German-language website (fifa.com/de) in connection with ticket sales for the 2022 FIFA World Cup in Qatar. After issuing a formal warning (Abmahnung) to FIFA on November 17, 2022, which FIFA declined to honor, VZBV filed suit in 2023.

The contested statements appeared under a "Sustainability" tab on FIFA's German-language ticket website and included: (1) a commitment that FIFA and Qatar would host "a fully climate-neutral FIFA tournament in 2022"; (2) a description of the sustainability strategy as including "energy-efficient stadiums, low-emission transport and sustainable waste management"; and (3) an assurance that "remaining unavoidable emissions will be offset to ensure a fully CO₂-neutral event."

On October 16, 2025, the court upheld the claim in full, finding that all three categories of statements constituted misleading commercial practices under § 5 Abs. 1, Abs. 2 Nr. 1 UWG. The court applied the strict standards the Bundesgerichtshof (BGH) had established for environmental advertising in its June 2024 ruling in Wettbewerbszentrale v. Katjes Fassin GmbH (BGH I ZR 98/23 — "klimaneutral"), which it explicitly cited, holding that environmental claims must meet heightened requirements of accuracy, clarity, and transparency because of consumers' elevated environmental awareness and the risk that vague "green" language disproportionately influences purchasing decisions.

The court found FIFA's disclosures insufficient on multiple grounds. First, FIFA never disclosed the ratio of actual emissions reductions to offsetting, creating a risk that consumers would overestimate the share of genuine reductions, especially given the BGH-established principle that emissions reduction takes precedence over compensation. Second, sub-claims about "energy-efficient stadiums," "low-emission transport," and "sustainable waste management" were themselves vague and undefined, lacking any benchmarks or concrete metrics. Third, the substantiating information was accessible only via hyperlinks to documents written exclusively in English (and partly Arabic), which the court held insufficient for German consumers, as advertisers cannot discharge their disclosure obligations by referring consumers to foreign-language sources.

The court rejected FIFA's argument that exact emissions data had not yet been available at the time of advertising, holding that FIFA was at a minimum obliged to disclose projected magnitudes and the types of offsetting planned. The court also confirmed a risk of repetition (Wiederholungsgefahr) on the basis that FIFA's sustainability page had historically referenced multiple past tournaments, making future use of the contested statements foreseeable even after the Qatar tournament had concluded.

The court ordered FIFA to refrain from making the three categories of statements in connection with ticket sales for any FIFA-organized World Cup, subject to a penalty of up to €250,000 per violation, and to reimburse vzbv's warning costs (€242.99 plus interest). The judgment is provisionally enforceable but not yet final (nicht rechtskräftig).