ESG Journal

Greenwashing: What It Is and the EU Rules Now in Force

Potted palm in a square grey planter standing against a white wall

Greenwashing is the practice of making a product, project or company look more environmentally friendly than it really is, through vague, exaggerated or unsupported claims. It stopped being only a reputational risk in the European Union on 27 September 2026, when the Empowering Consumers for the Green Transition Directive began to apply and put a list of misleading environmental practices on the banned list for marketing to consumers.

Key takeaways

  • Greenwashing covers vague wording, claims without evidence, selective facts, self-made labels and promises about the future with no plan behind them.
  • Directive (EU) 2024/825 applies from 27 September 2026 and bans generic environmental claims, offset-based neutrality claims, unapproved sustainability labels, whole-product claims that cover only one part and unsupported future claims.
  • It covers marketing to consumers by any business that sells to EU consumers, wherever the business is based.
  • On 28 May 2026 the European Commission opened infringement procedures against 20 member states that had not notified full transposition, so national implementation is still uneven.
  • The safest route is specific claims, kept evidence, recognised certification and a named owner for claim approval.

What is greenwashing and how does it work?

Greenwashing works by creating an impression that the facts do not support. The word was coined in 1986 by the environmentalist Jay Westerveld, and it joins “green” with “whitewashing”. Common forms include vague words such as “eco” or “green”, numbers without context, a single positive feature that hides larger impacts, labels invented by the seller and aspirations presented as achievements.

Our articles in this series explain the pieces in more depth. What greenwashing means covers the definition and the stalled Green Claims Directive, a greenwashing example walks through a court ruling, and companies greenwashing risk covers the build-up to the deadline.

What changed on 27 September 2026?

Directive (EU) 2024/825 was published in the Official Journal on 6 March 2024 and entered into force on 26 March 2024. Member states had to adopt it into national law by 27 March 2026, and the rules apply from 27 September 2026. The text on EUR-Lex adds practices to the list of commercial practices that are considered unfair in all circumstances, so authorities do not have to prove in each case that a consumer was misled. The main bans are:

  • Generic environmental claims, such as “eco-friendly”, “green” or “climate friendly”, unless the trader can demonstrate recognised excellent environmental performance, for example through the EU Ecolabel.
  • Claims that a product has a neutral, reduced or positive impact on emissions based on offsetting.
  • Sustainability labels that are not based on a certification scheme or established by public authorities.
  • Environmental claims about the whole product or business when they concern only part of it.
  • Claims about future environmental performance, such as “net zero by 2035”, unless they rest on a detailed, realistic implementation plan with measurable targets that an independent expert verifies.

Which claims are risky now, and how can you reword them?

Wording that was common a year ago now needs evidence. As a hypothetical example, “eco-friendly sofa” becomes a problem, while “frame made from timber certified under a recognised chain-of-custody scheme, with a cover containing recycled fibre according to the supplier’s declaration” can be proven. A “carbon neutral” product badge that depends on purchased offsets cannot be used, though a company can describe its offset project separately and accurately. A promise such as “net zero by 2040” needs a published plan with milestones and independent checks before it appears in consumer marketing.

The same reasoning applies to buildings. A homebuyer brochure that calls a development “sustainable” should say which measurable features support it, such as an energy rating, a heating system or a certificate, and should give their source.

How are the rules enforced?

Enforcement belongs to national consumer protection authorities and courts, which follow the national laws that transpose the directive. The Commission opened infringement procedures on 28 May 2026 against 20 member states that had not notified full transposition, according to law-firm reports, which shows that implementation remains uneven. Businesses should not read gaps in national law as a reason to wait, because the directive applies to businesses selling to EU consumers and the Commission is pressing member states to complete their work.

What should designers and companies do now?

  1. Audit every consumer-facing environmental claim in packaging, websites, brochures, social posts and award entries.
  2. Replace generic words with specific statements that name the benefit, the scope and the evidence.
  3. Check each label or badge for an independent certification scheme or a public-authority basis.
  4. Remove offset-based neutrality claims for products and stop publishing unsupported future targets.
  5. Keep a claims register with the evidence and a review date, and name an owner for approval.
  6. Read our guide to sustainable marketing for ways to describe progress honestly.

Frequently asked questions

Is greenwashing illegal?

In the European Union, misleading environmental claims were already prohibited under unfair commercial practices law, and since 27 September 2026 several specific greenwashing practices are banned outright in marketing to consumers. Elsewhere the answer depends on national consumer and advertising law.

Do the EU rules apply to businesses outside Europe?

Yes, if they market to consumers in the European Union. The directive applies to practices directed at EU consumers, wherever the business is based, so international studios, manufacturers and online sellers need to check their claims.

How can I report greenwashing?

Consumers can report misleading environmental claims to their national consumer protection authority or advertising regulator, and many authorities accept complaints online. Keep a copy of the advert or web page, the date and the product concerned.