Green claims: the rules, the loopholes and the cases

Greenwashing is environmental marketing that is misleading: claims that are vague, exaggerated, unsubstantiated, or that hide important information. It does not have to be a lie; a literally true statement can still mislead if the overall impression is wrong.

Food is especially exposed. Most people want to make better choices, but the footprint of a product is invisible at the point of sale. Claims about packaging, offsets or a single ingredient are easier to make than changing what the product is.

Regulators in Europe, the United Kingdom and the United States judge claims by how an ordinary consumer would understand them, and they expect companies to hold evidence before a claim is made — not after it is challenged.

Directive (EU) 2024/825, on empowering consumers for the green transition, amends EU consumer law. Member states must apply its rules from 27 September 2026.

It bans generic environmental claims such as 'environmentally friendly', 'green', 'eco' or 'climate friendly' unless the trader can demonstrate recognised excellent environmental performance relevant to the claim. It also bans claims that a product has a neutral, reduced or positive impact on the climate when they are based on greenhouse gas offsetting.

The directive also prohibits sustainability labels that are not based on a certification scheme or established by public authorities, claims about a whole product when the benefit concerns only one part, and claims about future environmental performance without clear commitments, a detailed implementation plan and regular independent verification.

The Competition and Markets Authority's Green Claims Code sets out six principles. Claims must be truthful and accurate; clear and unambiguous; must not omit or hide important information; must make fair and meaningful comparisons; must consider the full life cycle of the product; and must be substantiated.

Since April 2025, under the Digital Markets, Competition and Consumers Act 2024, the regulator can decide directly whether consumer law has been broken and impose fines of up to 10% of a company's global turnover.

Advertising is also policed by the Advertising Standards Authority, which has repeatedly ruled against vague or unsubstantiated environmental claims, including in food and drink.

The Federal Trade Commission's Green Guides explain how the law against deceptive advertising applies to environmental claims. They warn that unqualified general claims such as 'eco-friendly' are very difficult to substantiate and should be avoided or clearly qualified.

The guides also cover carbon offsets, recyclability, compostability and certifications and seals of approval. They were last revised in 2012, and a review began in 2022.

State attorneys general can also act under state consumer protection laws, as the case of the world's largest meat company shows below.

An offset is a credit that is supposed to represent one tonne of CO₂e avoided or removed somewhere else. The product's own emissions do not change.

A 2023 investigation by The Guardian, Die Zeit and SourceMaterial examined rainforest protection credits approved by Verra, the leading offset standard, and concluded that more than 90% were likely 'phantom credits' that did not represent real reductions. Verra disputed the findings, but the case illustrates familiar problems: inflated baselines, displaced deforestation and impermanence.

Even high-quality carbon removals are scarce and are best kept for genuinely unavoidable emissions. When a food claims to be carbon neutral, ask what was reduced first — and remember that the EU now bans such product claims when they rely on offsetting.

In March 2024, Denmark's Western High Court ruled that Danish Crown, Europe's largest pork producer, had misled consumers with packaging labels describing its meat as 'climate-controlled pork'. The case was brought by the Danish Vegetarian Society and the Climate Movement in Denmark.

The court found that the slogan 'Danish pork is more climate-friendly than you think' was a relative statement and not misleading, but that the 'climate-controlled' label breached the Danish Marketing Practices Act.

The lesson: labels that sound like certifications deserve the closest scrutiny, especially when they appear on products with high footprints.

In February 2024, New York's Attorney General sued JBS USA, the US subsidiary of the world's largest beef producer, alleging that advertising a goal of net zero emissions by 2040 misled consumers because the company had no viable plan to achieve it while planning to increase production.

A court dismissed the first complaint in January 2025 without prejudice, and the investigation continued. In November 2025, the company agreed to a $1.1 million settlement, to revise its net-zero statements and to report to the Attorney General's office for three years.

The lesson: long-range pledges without interim targets, a credible plan and full value-chain emissions are promises, not performance.

Good claims are specific: they say what is better, by how much, compared with what, and where the evidence can be found. Vague claims rely on colours, leaves and words like 'natural', 'responsible' or 'planet-friendly'.

Compare across food types, not just within one category. A 'lower-carbon' beef burger may still have many times the footprint of a bean burger. And remember that for most foods, what is inside the packet matters far more than the packet itself.

Ask what a label actually certifies. An animal welfare label is not a climate label, and a recyclable pack says nothing about the farm. Look for independent, recognised schemes with published criteria.

Ask the company for its evidence, publicly if you can. Questions in reviews, emails or social media make it clear that claims are being read critically.

Report misleading claims to the relevant authority: the Advertising Standards Authority or the Competition and Markets Authority in the UK, your national consumer protection authority in the EU, or the Federal Trade Commission or your state attorney general in the US.

Use our claim checker to identify red flags in wording, and share what you learn. Each challenge makes vague claims riskier for companies — and honest information easier for everyone else.