Greenwashing fines in Poland: how high are they and what does UOKiK charge companies for?

Consumers are ready to pay more for a product that is meant to be better for the environment. In a survey of over 20,000 people in 31 countries, they said they would pay 9.7% more (PwC Voice of the Consumer, 2024). But for this extra money they often get only a slogan. In 2020, the European Commission analysed 150 environmental claims used in the EU. It found 53.3% vague, misleading or unfounded, and 40% had no evidence at all (European Commission, 2023). This gap led to new EU rules, and in Poland to the first charges from the President of UOKiK, the national consumer protection authority.

• Maximum fine: up to 10% of annual turnover, separately for each challenged practice.
• Legal basis: the rules in force today, not the new law.
• Charges so far: Allegro, DHL, DPD, InPost, Bolt, Tchibo, Zara, L'Oréal Polska.
• New law: comes into force on 27 September 2027 and adds a closed list of practices banned in all cases.

How high are UOKiK fines?

The President of the Office of Competition and Consumer Protection (UOKiK) imposes fines for greenwashing in Poland. The basis is the ban on practices that harm the collective interests of consumers. The upper limit is 10% of the turnover in the year before the fine. Three things have a big effect on the scale of the risk:

1. Turnover counts, not profit. The basis is the revenue of the whole company, not the margin on the product the slogan was about.
2. The limit applies to each practice separately. In the courier case, one company faced six charges, and each has its own ceiling.
3. Negligence is enough. UOKiK does not have to prove an intent to mislead. The effect on the consumer is enough.

The fine is not the only cost. The UOKiK decision is public and usually reaches the media under the company's name. The office can also order the company to publish a statement about the breach and to remove its effects. For a brand that built its message around responsibility, this is harder to recover from than a payment.

In my experience, many breaches do not come from a wish to mislead customers. They come from the usual marketing wish to show a product at its best. The problem is that the marketing team often has no access to the detailed data needed to prove a slogan. And the environmental team does not see the creative work before it goes out.

This gap between the two teams is one of the most common sources of risk. There is one more problem. Neither marketing nor the people responsible for environmental or ESG issues often realise that general slogans are no longer enough. More and more often, you must state exactly what a claim covers and which data it rests on.

What has UOKiK charged companies for? Four cases from the Polish market

So far, UOKiK has brought greenwashing charges in three proceedings, and in a fourth case it gave its view in court:

1. 29 July 2025, couriers and e-commerce. Charges for four companies: DPD faced six, DHL four, InPost three and Allegro two. The slogans included "green fleet" and "ZERO emissions" while most vehicles still burned fuel, and "zero-emission e-commerce". Another claimed that one parcel locker cuts as much CO₂ a day as nine trees do in a year. A carbon footprint calculator also left out how customers collect their parcels.
2. 19 January 2026, Bolt, Tchibo and Zara. Bolt for "zero-emission vehicles" and "100% renewable energy" based on certificates rather than on direct energy purchases. Tchibo for "eco" and "sustainable" with no explanation of the criteria, and for presenting capsule recycling as general, although it covered only Germany and Austria. Zara for its "Join Life" campaign with claims about zero waste and net zero, with no scope or scale.
3. 16 September 2026, L'Oréal Polska. The charge concerns an A to E environmental rating system shown on the Garnier website from August 2021 to June 2025. Consumers were not told clearly that products were compared only within the L'Oréal group, not with the market.
4. Nałęczowianka, a court case. Here UOKiK does not run its own proceedings. It gave its view in a lawsuit brought by the ClientEarth foundation. The dispute concerns a bottle "100% made from other bottles" and "100% recyclable", with exceptions for caps and labels placed separately, in small print.

The L'Oréal case is especially interesting, because the rating system had a scientific basis and outside checks. Independent experts helped to develop it, and Bureau Veritas checked the method, the data and how the data was used in the ratings. In 2024, it confirmed that the method met six audited criteria, including scientific and technical soundness, consistency and accurate calculations. Even so, UOKiK challenged the way the result was shown to consumers. So outside verification of data or method does not make an environmental claim safe by itself. What you tell the reader matters just as much: the point of comparison, and whether the limits of the method are clear.

Six practices that keep coming back in the charges

Side by side, the cases form a repeated list of mistakes. If you recognise any of them in your company, you have the same problem as the companies above:

1. Zero when it is not zero. "Zero-emission", "ZERO emissions" or "emission-free" when most operations still burn fuel.
2. A hundred percent with no scope. "100% renewable" or "100% recycled" without saying what exactly the hundred percent covers and where it comes from.
3. A certificate instead of a fact. Guarantees of origin you bought, presented as a physical supply of green power.
4. Compensation instead of reduction. Tree planting and local projects described as if they cancelled the emissions of the core business.
5. A comparison within your own shelf. Ratings and rankings that suggest an advantage over the market, when the reference is only your own range.
6. A number with no method. Calculators and figures that leave out a large part of the life cycle, for example how the customer collects an order.

One thing links them all: the message promises more than the real effect of the product or the company on the environment. You do not have to lie to fall into this trap. It is enough to describe one green part of your business as if it covered the whole.

How long does it take from the first question to a charge?

In February 2023, the office opened explanatory proceedings in the clothing and cosmetics sectors and into an online marketplace. By May 2024 there were eight. The list included Allegro, Bielenda, Dr Irena Eris, H&M, KappAhl Polska, L'Oréal Polska, LPP and Zara Polska. The first charges came only in 2025.

This difference matters. Explanatory proceedings concern an issue, not a specific company. They do not end with a fine and usually stay out of the headlines. But they are the waiting room before charges, and the names show it. Allegro, Zara and L'Oréal Polska were checked from 2023 and heard charges in July 2025, January 2026 and September 2026. Two to three years passed from the office's first question to the charge.

In May 2024, UOKiK had received six consumer complaints about greenwashing in total. So a wave of reports is not needed to start proceedings.

Has UOKiK fined companies for similar claims before? Clothing content cases

There are no fines yet for greenwashing as such. But the office has fined companies for years, and with real amounts, for a related breach: false information about what a product is made of. In March 2022, UOKiK fined three makers of men's formal wear over PLN 2.1 million in total for false fibre content. They were Kubenz, Recman and Dastan Logistics. In August 2023, Lavard and Lord faced charges in the same matter. In April 2024, the decisions followed: over PLN 3.8 million for Polskie Sklepy Odzieżowe (Lavard) and over PLN 213,000 for Lord. The decisions are not final.

Why does this matter for environmental claims? Because the legal basis is the same: misleading consumers about the features of a product. In the decision on Recman, the office also wrote a thesis that legal writers now quote. Information about the effect of a product and its packaging on the environment can be material for consumers. That means that distorting it affects their decision to buy. So cases about wool content and cases about "zero emissions" rest on the same rule. They have only reached different stages.

Why does the delay of the EmpCo law suspend nothing?

Directive (EU) 2024/825, known as EmpCo, was to apply in EU countries from 27 September 2026. Poland transposes it with an act of 4 September 2026 amending the act on unfair market practices and the consumer rights act. It comes into force on 27 September 2027, a year after the deadline in the directive.

People often draw the wrong conclusion from this. The delay concerns the new list of banned practices, not liability for misleading consumers. That liability comes from the act on unfair market practices and from the ban on practices that harm the collective interests of consumers. It applies without change. All the charges described above rest on this basis, including the one from 16 September 2026.

It is also worth clearing up a confusion of names. The Green Claims Directive is a different, proposed act. It was meant to require checks of environmental claims before use, but the European Commission has stepped back from it. EmpCo is a separate act, already adopted and applied in the EU. Headlines about the withdrawn directive concern the first one and say nothing about the duties under the second.

None of the three greenwashing proceedings has ended with a decision yet. So there is still no final fine for greenwashing as such in Poland. But the clothing cases show how long the road from charge to amount is, and that the amount can run to seven figures.

In practice, this means one thing: the year of delay is not a grace period for your messages. It is time to put them in order. A company that treats it as permission for the status quo may collect charges under the old rules in the meantime.

What applies to greenwashing in Poland in 2026?

The table compares the rules today with the rules from 27 September 2027:

Today there is no official list of slogans banned in advance. But that does not mean that anything goes. It only means that misleading claims are judged in a specific case, from the view of an average consumer.

The new ISO 14021:2026 standard, published in June 2026, is a good reference here. It is not law, but it sets rules for self-declared environmental claims and refers directly to cutting the risk of greenwashing. It requires claims to be justified, precise, verifiable and based on documented data.

How do you check your own environmental claims before the office does?

A review of your own content takes a few days and is the cheapest moment in this whole story. This order of questions catches the most:

1. Collect everything you have published. Packaging, the website, product pages, sales materials, posts, customer presentations and answers to supplier surveys.
2. Add evidence to each claim. A specific document: a report, a calculation, a certificate, a verifier's statement. No evidence means a ready charge.
3. Check the scope. Does the slogan cover a product, a line or the whole company; one market or all; one life cycle stage or all?
4. Separate reduction from compensation. Say how much emissions really fell and how much you covered with credits. Mixing the two is now the most common charge.
5. Move from adjectives to numbers. "We cut Scope 1 and 2 emissions by 18% compared with 2021" will hold up; "we care for the planet" holds up nothing.
6. Show clearly what you compare the product with. If you use "better", "greener" or your own rating scale, the reader should know the point of reference at once. A comparison only with your own products, or under your own system, can mislead if you do not say so clearly.

The simplest example of greenwashing and its corrected version, for the same product:

• Will not hold up: "Environmentally friendly packaging". It is not clear what is friendly, compared with what, and on what basis.
• Will hold up: "Packaging made of 82% recycled material (by mass, without cap and label), confirmed by the supplier's specification from March 2026".

The difference is not that the second sentence is more careful. It is that you can check it, and the real scope of the benefit is visible. The same rule applies to services, not only to physical products: "climate neutral delivery" needs exactly the same evidence as packaging.

ISO 14021, which covers self-declared environmental claims, gives the formal frame for this work. It requires a claim to be specific, documented and verifiable. We show how this works in practice in the article on environmental labels and declarations: Type I, II and III. You will find a catalogue of misuses in what is greenwashing and in our guide on how to avoid greenwashing.

Do you want to know whether your company's claims will hold up?

We check this in a green claims audit. We review packaging, the website and sales materials, point out claims without support and suggest what to replace them with. Verification against ISO 14021 assesses a single claim, and independent carbon footprint verification checks the figures behind it.

If you are only building the data for your communication, start with a corporate carbon footprint or an LCA study.