Communicating Sustainability: How to Avoid Greenwashing

• The EU proposed a Green Claims Directive (GCD), but its future is uncertain.
• The Empowering Consumers for the Green Transition Directive (EmpCo) — adopted in 2024, effective from 2026 – bans vague environmental claims (like “eco” or “green”) unless they are backed by clear, verifiable evidence.
• Even without GCD, companies should expect regulation – either through green claims rules or consumer protection law (including EmpCo).
• Misleading or vague claims can already be treated as unfair commercial practices, leading to fines and reputational damage.

• Once a company is exposed for misleading environmental claims, the damage can be swift and long-lasting.
• Stakeholders (customers, investors, regulators) are increasingly alert.
• The fact that the GCD is paused doesn’t mean tolerance for misleading claims has increased – quite the opposite. Transparency and credibility are becoming competitive advantages.

• Misleading claims undermine consumer trust in sustainability in general.
• They distort competition: companies making genuine efforts may be unfairly disadvantaged.
• They delay real environmental progress.

• Employees, especially those involved in sustainability, expect integrity. If internal action doesn’t match public claims, morale and trust suffer.
• Long-term strategy suffers if marketing is ahead of reality.

Greenwashing imposes a strategic risk with legal, financial, and reputational consequences. In the long run, honesty, transparency, and gradual but real steps toward sustainability pay off.

• Empowering Consumers for the Green Transition Directive (EmpCo; EU 2024/825) is in force and requires transposition by Member States. Full binding effect from 27 September 2026.
• EmpCo includes “blacklist” provisions: certain environmental claims are automatically considered misleading, unless specific conditions are met. These include vague terms (“eco”, “natural”) without proven credentials; claims of environmental neutrality or improvements without credible, verifiable plans; claims that rely solely on offsetting.
• The Green Claims Directive proposal has been withdrawn / paused. In particular, the Commission has announced its intention to withdraw it on 20 June 2025. Negotiations are not currently moving forward.
• Stakeholders are closely watching whether a revised version might appear later. If so, one expects lighter burdens on small and micro-enterprises, clearer thresholds, possibly scaled requirements, and more alignment with existing laws (EmpCo, UCPD).

• Marketing campaigns: Some nature-related initiatives or projects communicate very ambitious goals but lack transparency about how funds are used or what impact the activities really have. This often results in public distrust and reputational harm – even if there are no immediate regulatory penalties.
• Investment sector: Certain institutions publicly present sustainability as a core value and claim to hold a high share of “green investments.” However, audits have revealed that the reality often differs – marketing claims don’t match actual portfolio composition. In some cases, this has led to regulatory investigations and fines worth tens of millions of euros.
• Financial sector: A company may present itself as a sustainability partner and actively support ESG-related events, while simultaneously providing services to sectors with significant negative climate impact. When such information becomes public, the company’s reputation is threatened, and stakeholder pressure may force it to rethink its policies – for example, by ending cooperation with high-emission industries.
• European context: Recent cases show companies fined or investigated by national authorities for misleading claims – typically around “carbon neutrality” based solely on offsetting without clear justification.

• Tesco Czech Republic: The first company in the country to publicly report food waste volumes in its stores and warehouses back in 2017. Thanks to this and other measures, they reduced food waste by 80% by 2024. Transparent reporting and concrete targets help Tesco build credibility and avoid greenwashing.
• LEGO: The company abandoned its plan to replace ABS plastic with recycled plastic (rPET) when it realized that the material was too soft and would require additional components and more energy to achieve durability—resulting in a higher carbon footprint.
• Patagonia: Communicates openly about potentially problematic impacts of its production.

• Focus on quick wins: Use our Honesty filter to immediately eliminate the biggest greenwashing risks.
• Develop a credible ESG strategy: Base ESG on facts and link it to your business strategy. We can help you design or review it – including setting goals, key messages, and communication priorities.
• Ensure company–wide ESG alignment: Organize regular ESG strategy meetings with management, communications, and other key departments. We offer facilitation of these workshops and tailored in-house training.
• Adjust your public sustainability presentation: Redesign your website, marketing materials, and product descriptions to align with your ESG strategy and Green Claims Directive requirements. We can help shape your sustainability story and communication strategy.
• Keep your claims and data up to date: Maintain environmental claims that are current and evidence-based – set up processes to verify and report them in line with legislation.