Greenwashing explained: meaning, examples and rules

Greenwashing means that a company presents a product, a service or the organisation itself as more sustainable than the facts allow. That can be done with words like green or climate neutral, but also with a leaf on the packaging or a logo you designed yourself. Since 27 September 2026, a large part of these practices has also been prohibited by law in the EU. In this article we explain what greenwashing is and what it is not, which forms you come across, which companies have recently been called out for it and what the rules now require of you.

At Empact, we can get immensely annoyed by people who call out on occasion that a sustainability claim is false. Sure, greenwashing is a problem that needs to be addressed. But if too many companies keep their green ambitions under the table precisely because they fear being accused of greenwashing, precious opportunities for change are lost. After all, the sustainability transition is not a matter of right and wrong, but of doing. So do you have green products, services, plans or ambitions? Then communicate them to the outside world, but be honest.

The importance of a green and fair image

Your image determines how customers, investors and policymakers view your company or brand, and is thus a decisive success factor. Important values that you want to project as a company include reliability and sustainability. What many companies struggle with is how to best unite these two values in their image. In other words, how do you communicate your sustainability performance honestly yet as convincingly as possible?

If you are too cautious in this, you run the risk of being seen as a laggard. Staying silent out of fear even has a name by now: greenhushing. And when you make claims that are too implausible, you are unreliable and can be accused of greenwashing. Where do you draw the line?

What is greenwashing and what is it not?

Greenwashing is deliberately pretending to be greener than you are. So it is a way to improve your image with deception. It is a serious corporate sin, as is falsely accusing a company of greenwashing. After all, if it turns out that you have not been honest about sustainability, from then on you are not only less reliable in the eyes of many, but also less sustainable. So not good for your image, and bad for your business.

A textbook example of greenwashing is Shell with, among other things, their campaign about CO2-neutral petrol. An absurd sounding claim of course, which the Dutch Advertising Code Committee called misleading in 2021. By now the law prohibits such a claim as well: climate neutral or CO2 neutral based on offsetting has not been allowed since 27 September 2026. It is bizarre in the first place for one of the world’s biggest polluters to present itself as sustainable.

A textbook example of what greenwashing is not is the accusation against Dopper that they are not so sustainable after all because there is plastic in their bottles. That there is plastic in it is indeed true, but that plastic is 100% recyclable, unlike all those PET bottles. Furthermore, sustainability is woven into Dopper’s DNA, so it’s hard to say they’re “faking it”.

Seven forms of greenwashing

Greenwashing is rarely an outright lie; usually it lies in what you leave out or make look better than it is. The Canadian consultancy TerraChoice reduced the variants to six sins in 2007 and added a seventh in 2009. That classification is still in use. If you recognise one of them in your own communication, that is the moment to hold the claim up against the evidence once more.

1. The hidden trade-off. Highlighting one green aspect and keeping quiet about the rest. Think of paper from responsibly managed forests, produced with a lot of energy and water.
2. No proof. A claim nobody can verify, such as “contains recycled material” without a percentage or certificate.
3. Vagueness. Words that mean everything and nothing: green, natural, eco, conscious.
4. False labels. A logo that looks like a certification label, but has not been checked independently by anyone.
5. Irrelevance. Promising something that is required anyway, such as a spray can advertising “CFC-free” while CFCs have been banned for decades.
6. The lesser of two evils. A green label on a product whose category is the problem, such as a fuel-efficient SUV.
7. Lying. Claims that are simply untrue, for example mentioning a certification you do not have.

Four of these seven return in the European rules that have applied since 27 September 2026: a generic claim without recognised performance, a claim about one part that seems to cover the whole product, a legal requirement presented as a plus and a label without independent verification. We come back to this below.

Recent examples of greenwashing

Anyone who greenwashes today risks more than a dent in their image. A few cases from recent years show where the line is:

• KLM (March 2024). The Amsterdam District Court ruled that fifteen of the nineteen challenged statements, including Fly Responsibly and CO2ZERO, were misleading. Offsetting by planting trees does not reduce actual emissions, according to the court.
• 21 airlines (November 2025). After a joint action by the European consumer protection authorities, including the Netherlands Authority for Consumers and Markets (ACM), they committed to no longer making offsetting or neutrality claims.
• De Bijenkorf (September 2025). The Dutch department store changed unclear sustainability claims on its website after action by the ACM.
• Coffee and cocoa (2025 and 2026). In August 2025 the ACM examined the claims in this sector. In February 2026 Nestlé, Mondelez and JDE Peet’s committed to dropping vague terms and adjusting their own logos.

We describe more Dutch cases, from Albert Heijn to Zalando, in our article on the Empower Consumer Act.

What does the law say?

Since 27 September 2026, stricter rules for sustainability claims have applied in the Netherlands and in most other EU countries. They come from the European directive usually referred to as the Empower Consumer Act (EmpCo), officially Directive (EU) 2024/825. In the Netherlands they are laid down in the Civil Code, as part of the rules on unfair commercial practices. Not every member state has transposed the directive yet; in the Netherlands it does apply. The core in five points:

• Generic claims only with recognised performance. Green, environmentally friendly or eco is only allowed if there is a recognised, excellent environmental performance behind it, for example an EU Ecolabel. Sustainable and conscious are not allowed even then, because those words also say something about social aspects. A claim you make concrete in the same statement and can prove remains perfectly possible.
• Climate neutral based on offsetting is prohibited. Climate neutral, CO2 neutral or net zero is no longer allowed if the claim rests solely on offsetting outside your own value chain.
• Only genuine labels. A sustainability logo is only allowed if it was established by public authorities or is based on a certification scheme with independent verification. A self-designed logo is no longer allowed.
• Future promises only with a plan. Climate neutral by 2030 is only allowed with a concrete, public and independently verified plan with interim steps.
• No part for the whole and no obligation as a plus. A claim that only covers one part while it seems to cover the whole product counts as misleading. The same goes for something the law already requires that you present as a special benefit, such as gluten-free bottled water.

The ACM supervises compliance and can impose fines of up to 900,000 euros or, if that is higher, 1% of annual turnover; for a breach of the blacklist even up to 10%. In addition, competitors and interest groups can go to court, as Fossielvrij NL did against KLM. The five rules of thumb from the ACM’s Guidelines on Sustainability Claims remain a good starting point, although the ACM itself notes that these guidelines reflect the situation in 2023.

The Green Claims Directive, a second European directive that would have regulated how claims must be verified in advance, has been on hold since June 2025. In practice, EmpCo is what counts. How that law works exactly, you can read in our article on the Empower Consumer Act. Which sentences no longer work as a result, and what you write instead, is set out in seven sustainability claims that are no longer allowed. What a certification label or ecolabel is worth today, you can read in our article on ecolabels.

Tips for making green claims without being accused of greenwashing

Our sustainability consultants will be happy to help you find a way to communicate your sustainability performance to the outside world in a sincere and effective way. Here are four tips to get you started communicating honestly and effectively about sustainability.

Make only claims that you can substantiate

It is important that you can provide evidence to support the green claims you make. Not only does this make your claim more convincing, but if you do get accused of greenwashing, you can explain why not. For example, have a life cycle analysis (LCA) performed for your products, and refer to specific results from this analysis in your communications. Think about the number of kilos of plastic you save or the tonnes of CO2 you don’t emit. Under the new rules, that evidence is moreover the condition for being allowed to make a claim at all.

Make sure claims are relevant

In addition, make sure that the sustainability claims you make relate to the product you are making them for. With energy companies, for example, you often see that they advertise green power and green energy, but only a small portion of the energy they supply is actually green. Banks are guilty of this too. When you open an account, you will see wind turbines in Flevoland everywhere on the home page, while meanwhile a large part of your money goes to coal-fired power plants. Another part also goes to wind turbines, but still, these kinds of “visual claims” are of course not entirely fair. The law now names this explicitly: a claim that seems to cover the whole product while it only covers one part counts as misleading.

Keep your communications up-to-date

It is also important to realise that the sustainability transition is an evolution, not a revolution (despite sometimes being called that). Thus, the world does not become sustainable overnight. This is a process. Technologies needed to live 100% sustainably are still under development, and we cannot use them (competitively) right now, for example. Think of green hydrogen and high-quality recycled plastic. At the same time, much more is possible today than ten years ago.

So making your business more sustainable is also a process. What this means for sustainability claims is that they can also be overtaken by time. What is currently “green” may be outdated within a few years. However, this is not to say that you shouldn’t communicate that 30% CO2 reduction in your logistics chain from last year now, because you are afraid that in some time it may be seen as greenwashing because it is no longer relevant. Just don’t let it stand for ten years. Let your communication move with your sustainability journey!

Don’t adopt a claim without the evidence

A claim from your supplier does not automatically cover you. If you put the manufacturer’s “made from recycled material” on your own packaging or website, you are responsible for it yourself, towards your customers and towards the regulator. So ask for the certificate, the LCA or the test results, and keep them with the claim. That way, when the ACM or a critical customer asks, you can show right away what the claim rests on.

Unsure about a claim?

Then run it through the free Greenwashing Check by Empact. You enter the claim, answer the questions that go with it and see per criterion whether it holds up, with the rule alongside. If the claim needs substantiation, you see which evidence question is still open. How the check works and what it does and does not do, you can read in our announcement of the launch. For seven common claims, we have already shown how you can phrase them instead. And if you want to go beyond the claim alone, towards a story that convinces consumers, read our eight strategies for communicating sustainability.