Greenwashing Guide
How to identify, avoid, and prevent greenwashing in your product submissions. Based on global regulatory standards effective in 2024–2026.
What is Greenwashing?
Greenwashing is the practice of making false, exaggerated, or misleading sustainability claims about a product, service, or company. It deceives consumers into believing they are making environmentally responsible choices when they may not be. Greenwashing undermines genuine sustainability efforts and is increasingly subject to legal enforcement worldwide.
Common Greenwashing Tactics
Greenlabelling
Using environmentally friendly labels, wording, or visuals to create a false impression of ecological responsibility.
Example
A product packaging with green forests and leaves printed on it, implying environmental benefit — when the product has no environmental certifications.
How to avoid
Only use eco-imagery if your product holds a recognised certification that substantiates the visual claim.
Greenlighting
Spotlighting a small or irrelevant environmentally beneficial feature to distract from broader negative impacts.
Example
A fast-fashion brand highlighting a single "conscious collection" made from recycled polyester, while 99% of their production uses virgin materials.
How to avoid
Be transparent about your product's full environmental footprint, not just the positive parts.
Greenshifting
Deflecting environmental responsibility onto consumers or other parties instead of taking ownership.
Example
A beverage company blaming consumers for not recycling enough, while producing billions of non-recyclable plastic bottles.
How to avoid
Take responsibility for your product's end-of-life impact. Don't shift blame to users.
Greenrinsing
Frequently changing or weakening environmental goals and targets without actually achieving them.
Example
A company publicly announcing ambitious carbon neutrality targets, then quietly walking them back years later without meeting them.
How to avoid
If you claim future environmental goals, provide a detailed, realistic implementation plan with timelines.
Greencrowding
Hiding within a group of similarly non-compliant companies to avoid individual accountability.
Example
An industry association publishing voluntary sustainability standards that are weaker than regulations, allowing members to appear responsible without real action.
How to avoid
Don't rely on industry averages or group commitments to justify your product's claims.
Greenhushing
Under-reporting or hiding sustainability data to avoid scrutiny, while still marketing as sustainable.
Example
A company selectively publishing only positive ESG metrics while omitting negative environmental data from their reports.
How to avoid
Disclose both positive and negative environmental impacts transparently.
Red Flags to Watch For
- Using vague terms like "eco-friendly", "green", "natural", "planet-friendly", or "clean" without specific substantiation
- Claiming "carbon neutral" or "net zero" without disclosing offset details or verification
- Displaying fake or self-created certification badges that are not from recognised third parties
- Making environmental claims about a minor product feature while ignoring major negative impacts
- Using green imagery (leaves, trees, earth) on products with no environmental benefit
- Claiming "100% recycled" or "biodegradable" without providing evidence or certification
- Advertising future environmental commitments without a detailed, verifiable implementation plan
- Highlighting a small "sustainable" product line while the core business remains unsustainable
- Claiming "free-of" a substance when that substance was never used in similar products anyway
- Making comparative environmental claims ("greener than") without identifying the basis of comparison
Do's & Don'ts
Use specific, verifiable claims like "100% of energy used comes from renewable sources"
Use vague claims like "eco-friendly" or "green"
Cite recognised third-party certifications (B Corp, ISO 14001, EU Ecolabel)
Create your own certification badge or logo
Provide evidence for every environmental claim you make
Make claims without documentation or data
Be transparent about both positive and negative impacts
Only highlight the good and hide the bad
Use precise language: "packaging contains 80% post-consumer recycled content"
Use broad language: "made with recycled materials"
Disclose carbon offset details if claiming carbon neutrality
Claim "carbon neutral" based solely on unverified offsets
Qualify claims that apply to only part of the product
Imply that a partial benefit applies to the whole product
Update claims if circumstances change
Leave outdated environmental claims on your product page
Regulatory Standards & Frameworks
The following standards define and regulate environmental claims globally. SOE aligns its anti-greenwashing policy with these frameworks.
EU Directive on Empowering Consumers for the Green Transition (ECGT)
EU Directive 2024/825
- Prohibits generic environmental claims ("eco-friendly", "green", "climate-friendly") without recognised excellent environmental performance
- Requires future environmental performance claims to be backed by detailed, realistic implementation plans verified by independent third parties
- Bans sustainability labels not based on certification schemes or established by public authorities
- Mandates that carbon neutrality claims based on offsetting must disclose whether emissions are reduced internally or offset
UK FCA Anti-Greenwashing Rule (SDR regime)
UK FCA SDR
- Sustainability claims must be "fair, clear, and not misleading"
- Claims must be substantiated with adequate evidence
- Requires consistency between marketing materials and actual sustainability performance
- Applies to all communications including labels, website, social media, and advertising
Canada Bill C-59 (Competition Act amendments)
Canada Bill C-59
- Explicitly prohibits deceptive environmental claims
- Requires adequate and proper testing to substantiate claims before they are made
- Strengthens enforcement powers including substantial penalties
- Applies to claims made in promotions, labelling, and marketing
EU Sustainable Finance Disclosure Regulation (SFDR) + ESMA Guidelines
EU SFDR + ESMA
- ESG fund naming rules: funds using "ESG" or "sustainable" in names must meet minimum thresholds
- Requires disclosure of how sustainability risks are integrated into investment decisions
- Anti-greenwashing provisions prohibit misleading sustainability claims in fund marketing
- ESMA guidelines enforce consistent classification and labelling
Corporate Sustainability Reporting Directive (CSRD)
EU CSRD
- Requires detailed sustainability reporting aligned with European Sustainability Reporting Standards (ESRS)
- Mandates assurance (verification) of sustainability information
- Raises the evidentiary bar for environmental claims in corporate reporting
- Requires double materiality assessment: financial and impact materiality
US FTC Green Guides
FTC Green Guides
- Prohibits broad, unqualified general environmental benefit claims ("green", "eco-friendly")
- Requires competent and reliable scientific evidence for all environmental claims
- Specific guidance on carbon offsets, certifications, compostable, degradable, free-of, recyclable, and recycled content claims
- Certifications must disclose material connections to certifying organizations
EU Unfair Commercial Practices Directive (UCPD) — 2024 amendment
EU UCPD (amended)
- Added specific greenwashing practices to the list of inherently unfair commercial practices
- Prohibits displaying sustainability labels not based on certification schemes
- Prohibits claiming that a product has a neutral impact on the environment based on offsetting when this is not the case
- Requires environmental claims to be based on recognised excellent environmental performance
Brazil Sustainability Reporting Standards
Brazil SRS
- Aligns with IFRS Sustainability Disclosure Standards (S1 and S2)
- Mandates assurance of sustainability information
- Requires substantiation of environmental claims with verifiable evidence
- Enforces stricter reporting on climate-related risks and opportunities
How SOE Enforces This
Mandatory acknowledgment
All submitters must confirm their product makes truthful, evidence-backed sustainability claims before launching.
Community reporting
Any authenticated user can report a product for greenwashing, misleading claims, or fake certifications using the Report button.
Automatic flagging
Products receiving 3+ reports are automatically flagged and removed from public listings pending review.
Immediate removal
Products confirmed to contain false or misleading sustainability claims are removed immediately from the platform.
Submitter accountability
Repeated violations result in suspension of product submission privileges and potential account termination.