Your marketing team wants to print “climate neutral” on a product. Sales want an “eco” badge for a tender. Since 27 September 2026, EU law bans product claims of climate neutrality based on offsets, and general “eco” claims without proof (Directive (EU) 2024/825). In the UK, the CMA checks the same claims against its Green Claims Code. It can now fine a company up to 10% of its global turnover.
- How to avoid greenwashing: base each environmental claim on evidence and say only what your company has really done.
- Evidence: a carbon footprint, a life cycle assessment or an EPD, with scope, base year and method.
- Labels: use certificates from an independent body, never your own badge that looks like one.
- Offsets: do not claim that a product is climate neutral because you bought carbon credits.
- Approval: marketing, ESG and legal teams check each claim before it goes live.
Eight rules to avoid greenwashing
The best protection is to treat each environmental claim as a statement you must prove. Start from what your company really does for the environment, not from an idea for a campaign. Make the change first and talk about it later. In this order, your message builds trust instead of putting it at risk. This applies to claims about products and services and to general statements about your company.
Eight rules help:
- Measure before you speak: calculate the carbon footprint of your company or the life cycle impact of a product before you talk about emissions. Without a starting point, you cannot show progress.
- Use specific evidence: a life cycle assessment, an environmental product declaration and data from your own processes, not general words.
- Use numbers, not adjectives: instead of “eco product”, say how much the carbon footprint fell, for what scope and against which year.
- Use recognised certificates: a mark from an independent body, such as a B Corp certificate, counts for more than your own label. You must be able to support each one with documents.
- Check the whole life cycle and supply chain: most of the real impact of products is there, including packaging and waste after use.
- Keep your claims in line with your ESG report: use the same method in marketing and in reporting. Report failures as well as successes.
- Do not confuse a gesture with a cut: planting trees or buying carbon credits does not cancel emissions from your own processes. It can add to real cuts, but it does not prove them.
- Do not use false labels: your own badge that looks like a certificate is banned. So is praise for a feature the law already requires.
These rules are not just good practice. Most of them come straight from Directive (EU) 2024/825. It treats general claims, false labels and neutrality based on offsets as practices that mislead consumers. For the definition and examples, read our article on what greenwashing is.
How to build evidence for an environmental claim?
Customers, banks and regulators now ask about sustainability, not only marketing teams. So your data should be close to financial data in quality. Evidence is not a statement from the board. It is numbers calculated with a recognised method. The right document depends on what the claim is about:
- claims about your company: a corporate carbon footprint in Scope 1, 2 and 3;
- claims about a product: a product carbon footprint or a full life cycle assessment (LCA);
- claims for business customers and tenders: an environmental product declaration (EPD), checked by an independent verifier.
Three things decide whether the evidence will stand up in front of a regulator or a customer:
- Scope: what exactly you calculated.
- Base year: what you compare the progress with.
- Current data: a claim based on a calculation from five years ago is almost as weak as a claim with no calculation.
Missing evidence is the most common cause of trouble. It is rarely bad faith. More often, a slogan ran ahead of the measurement. If you have no evidence, calculate the data or withdraw the claim. Softer wording does not help: a general claim without proof is a misleading practice in itself.
Honest marketing: transparency and customer trust
Greenwashing misleads consumers. This is why it hurts a company more than a typical marketing mistake. The damage goes beyond one brand. A consumer who feels cheated once starts to doubt all green claims in the category. Trust takes years to rebuild and one campaign to lose.
Transparency costs less than explaining yourself later. Share your method, scope and base year, so that a customer, investor, auditor or journalist can check the numbers. Talk about your successes and also about what you have not solved yet, including the negative impact that remains.
A method is not enough if it is biased. Some ratings compare a product only with other products of the same company. Others use criteria chosen to fit the company’s own result. Such a rating sounds objective, but it is not. Readers take it as information about the impact on the environment. In fact, they only learn how the product compares with others from the same producer.
The point of reference must not depend on the company that makes the claim. Use a recognised standard, sector data or a comparison with the market, not with your own range. If you use your own rating scale, say clearly what you compare with and what each grade means. The same rule applies to ratings from others, such as an EcoVadis medal.
A company that has sustainable practices and can document them has plenty to talk about. It usually has more than it thinks, but nobody has collected it in one place. Sustainability work told with numbers defends itself. It is also the cheapest way to report: the same data serve the report and the campaign.
Who is responsible for a claim? Roles and approval
Honest communication needs a procedure, not good intentions. The most common cause of trouble is not bad faith. It is the lack of one place where someone compares the slogan with the evidence. In practice, a simple split of roles works well:
- marketing proposes the claim and knows where it will appear: on a pack, in an ad or in a tender offer;
- the ESG team provides the evidence and checks that the claim matches what the company has really done;
- the legal team assesses the risk under consumer law and the guidance of consumer authorities, such as the CMA’s Green Claims Code.
Write the procedure down. State who approves a claim, on what evidence, where the source files are and when the claim needs a new calculation. Without this, the knowledge stays in one person’s head. When you change agencies or a specialist leaves, you start from zero.
Checklist before you publish a campaign
The most common traps are slogans without scope, false labels and neutrality based on offsets. You can catch all of them before a campaign goes live. Before your material reaches the public, ask eight questions. If the answer to any of them is “we don’t know”, the message needs a fix, not a launch:
- Does each claim have evidence that we can show on request?
- Have we given the scope, base year and method?
- Does the claim cover the whole product or only one part, and is this clear?
- Does our label look like a certificate from an independent body when it is not one?
- Is our claim of neutrality based only on offsets?
- Do the photos, colours and layout suggest more than the text says?
- Does the message match what our ESG report shows?
- Are we praising something that the law requires anyway?
For a large campaign, or for several brands at once, this review rarely fits into one meeting. In that case, a green claims audit helps. It is a structured review of slogans, evidence and the context in which they appear. Fixing a message before launch costs less than pulling a campaign or a print run of packaging.
Frequently asked questions
How can a company avoid greenwashing?+
Base each environmental claim on evidence: a carbon footprint, a life cycle assessment or an environmental product declaration. Say only what your company has really done, and give the scope, base year and method.
Is a certificate enough to avoid a greenwashing charge?+
It helps if it comes from an independent body and covers exactly what the message says. A company’s own label that does not come from a certification scheme counts as a misleading practice.
What should you do if a claim is already published and the evidence is missing?+
Withdraw or reword the claim, and calculate the data at the same time. The longer an unsupported claim stays on the market, the higher the risk of a case and the harder it is to repair your image.
Can you claim that a product is climate neutral because of offsets?+
No. Directive (EU) 2024/825 bans claims that a product has a neutral, reduced or positive impact on the climate based on offsetting emissions. EU countries apply the ban from 27 September 2026, although some are late: in Poland it applies from 27 September 2027. In the UK, the CMA can treat such a claim as misleading under consumer law.
Who in the company should approve environmental claims?+
Ideally three teams together. Marketing knows the context, the ESG team provides the evidence, and the legal team assesses the risk. Write the procedure down, so that the knowledge does not stay in one person’s head.
Do you need evidence for your environmental claims?
We calculate the carbon footprint of companies and products, carry out life cycle assessments and prepare environmental product declarations (EPD). These are the data you can base your claims on without the risk of a greenwashing charge. We also review claims that are already on the market in a green claims audit. If you do not yet know what to say, we start with an analysis of your product’s environmental advantages.