Greenwashing is no longer just a reputational risk. It's becoming a legal one. As regulators across the UK and Europe tighten the rules on environmental claims, businesses that make misleading sustainability statements face fines, legal action and lasting damage to customer trust. Here are five of the most common greenwashing mistakes, and how to avoid them.
Updated 7 Oct 2026: the EU section reflects the stalled Green Claims Directive and the new consumer rules that apply from 27 September 2026.
The regulatory landscape is shifting
The EU Green Claims Directive, proposed in 2023, would require companies to back environmental claims made to consumers with robust, independently verified evidence. In June 2025 the European Commission said it intended to withdraw the proposal, and the final round of negotiations was cancelled. At the time of this update it has not been adopted (European Parliament procedure file).
The EU rules that do apply come from the Unfair Commercial Practices Directive, as amended by Directive (EU) 2024/825 on consumers and the green transition. From 27 September 2026 it bans generic environmental claims, such as “eco-friendly”, that a business can't back with recognised excellent environmental performance, sustainability labels not based on a certification scheme or set by public authorities, and claims that a product has a neutral, reduced or positive climate impact because of offsetting.
National regulators are already acting. The UK's Competition and Markets Authority (CMA) published the Green Claims Code in 2021 and has investigated environmental claims in sectors such as fashion. Since April 2025 it can enforce consumer law directly, with fines of up to 10% of global turnover (CMA, April 2025). In the Netherlands, a court ruled in March 2024 that 15 of 19 environmental claims in KLM's advertising were misleading (Osborne Clarke summary).
The cost of getting caught greenwashing is no longer just a PR crisis. It's regulatory enforcement, financial penalties and legal action.
Mistake 1: Vague and unquantified claims
Phrases like “eco-friendly”, “green”, “sustainable” or “better for the planet” are the most common form of greenwashing. They sound positive but say nothing specific. The UK's Green Claims Code already expects every claim to be clear, accurate and backed by evidence, and from 27 September 2026 EU law bans generic claims like these unless you can show recognised excellent environmental performance.
The fix: replace vague language with specific, quantified claims. Instead of “Our packaging is sustainable”, say something like “Our packaging contains 80% post-consumer recycled content, which cuts its carbon footprint by 35% compared with virgin materials”, and only if your data shows it. Back every number with data, a stated method and, where possible, independent verification.
Mistake 2: Cherry-picking positive data
Highlighting one positive environmental metric while ignoring the broader picture is a subtle but common form of greenwashing. For example, a company might promote its renewable energy purchasing while leaving out that its Scope 3 emissions (the emissions in its supply chain) have risen by 40%.
The fix: present environmental performance in context. If you're highlighting progress in one area, acknowledge the challenges in others. Credible sustainability communication tells the full story, including the parts that aren't yet where you want them. Stakeholders respect honesty more than perfection.
Mistake 3: Misleading carbon neutral claims
Claims of “carbon neutrality” are under intense scrutiny. Many rely heavily on carbon offsets of questionable quality while actual emissions stay the same or even rise. Regulators and standards bodies are increasingly sceptical of claims that treat buying offsets as the same as cutting emissions, and in the EU, claiming a product is climate neutral because of offsetting is banned from 27 September 2026.
The fix: if you talk about carbon neutrality, be transparent about how it's achieved. Separate actual emissions reductions from offset purchases, and disclose the type and quality of any offsets. Better still, focus your messaging on measurable reductions in actual emissions. The Corporate Net-Zero Standard from the SBTi (the Science Based Targets initiative) gives a credible framework: cut emissions by 90% or more, then use permanent carbon removal for the residual fraction.
Mistake 4: Ignoring the full value chain
Many companies base their environmental claims on their direct operations (Scope 1 and 2) and ignore supply chain emissions (Scope 3), which often make up most of their footprint. Claiming to be “low carbon” while overlooking 80% of your emissions is misleading, even if it's unintentional.
The fix: be clear about the boundaries of your claims. If your reduction figures only cover Scope 1 and 2, say so explicitly. Better still, work towards full Scope 3 measurement and include the whole picture in what you publish. The Green Claims Code already says claims must not omit or hide important information, and must consider the full life cycle of the product or service.
Mistake 5: Using outdated or unverified data
Environmental claims based on data that is several years old, uses superseded emission factors or has never been independently reviewed are inherently unreliable. As assurance under the EU's Corporate Sustainability Reporting Directive (CSRD) and stronger consumer-law enforcement bring more scrutiny, unverified data is a liability.
The fix: make sure your emissions data is current, uses up-to-date emission factors and is reviewed or assured regularly. Keep a clear trail from raw data to published figures. If you make a public environmental claim, be ready to show the evidence behind it.
Building credible sustainability messaging
Avoiding greenwashing isn't about saying less. It's about saying things that are true, specific and substantiated. These principles underpin credible environmental communication:
- Be specific: quantify claims wherever possible. Use absolute numbers, percentages and clear baselines.
- Be honest: acknowledge challenges alongside achievements. Credibility comes from transparency, not from presenting a perfect image.
- Be comprehensive: consider the full life cycle and value chain. Don't hide negative impacts behind positive headlines.
- Be current: use recent data and up-to-date methods. State the period your claims refer to.
- Be verifiable: make sure every claim can be traced to evidence that would stand up to independent review.
The most powerful environmental claim is one that is boring in its precision: specific, quantified, independently verified and honest about its context.
Zoru helps you keep the evidence behind your figures. Every entry shows whether it has been reviewed, you can attach evidence files to entries, and changes have a tamper-evident history, so you can show where a number came from.