Eight practical principles to help brands, communicators and ESG teams talk about sustainability without slipping into greenwashing. Cross-referenced with ISO 14021 (International), FTC Green Guides (US), UK Green Claims Code — CMA (UK), CSRD / ESRS (EU), EU Directive 2024/825 — ECGT (EU), CSDDD (EU), EU Green Claims Directive (proposed) (EU), Australian Consumer Law — ACCC (AU), and Dutch ACM Sustainability Claims Guidelines (NL).
Why it matters
Vague terms like “eco-friendly,” “sustainable,” and “green” are prohibited under EU Directive 2024/825 unless backed by specific, verifiable evidence. Generic language is the most common greenwashing trigger.
“Our packaging uses 40% recycled content, certified by the Global Recycled Standard.”
“Our packaging is eco-friendly.”
Framework: EU 2024/825, ISO 14021
Why it matters
Claims must be substantiated with specific data, methodology, or third-party verification. A claim without evidence is a liability, not a differentiator.
“We reduced Scope 1 and 2 emissions by 32% between 2020 and 2024, verified by Bureau Veritas.”
“We are reducing our carbon footprint.”
Framework: CSRD/ESRS, ISO 14021, GHG Protocol
Note: Under the EU Omnibus Directive (EU 2026/470), mandatory CSRD reporting applies only to companies with more than 1,000 employees and more than €450 million net annual turnover. Companies below these thresholds are exempt but may face voluntary reporting expectations from investors and value chain partners.
Why it matters
Green leaves, wind turbines, and polar bears create an implied environmental claim even without words. Visual greenwashing is increasingly scrutinised by regulators.
Images that show actual sustainability initiatives with context and data.
Generic nature imagery used to imply environmental responsibility without substantiation.
Framework: EU 2024/825, FTC Green Guides
Why it matters
Highlighting one positive environmental metric while ignoring significant negative impacts is selective communication — a recognised greenwashing tactic.
“Our recycled packaging reduces plastic by 30%, though our products still require single-use applicators — a challenge we are actively working to address.”
“Our new sustainable packaging.” (while the product itself has significant environmental impact)
Framework: CSRD/ESRS, UK Green Claims Code
Note: Under the EU Omnibus Directive (EU 2026/470), mandatory CSRD reporting applies only to companies with more than 1,000 employees and more than €450 million net annual turnover. Companies below these thresholds are exempt but may face voluntary reporting expectations from investors and value chain partners.
Why it matters
Claims like “100% sustainable,” “zero emissions,” or “fully circular” require total proof across the entire lifecycle. Most cannot be substantiated.
“Our main packaging material is 100% recycled, based on our 2024 supplier audit.”
“100% sustainable product.”
Framework: ISO 14021, FTC Green Guides, EU 2024/825
Why it matters
A claim about a product should not imply something about the whole company, and vice versa. Scope confusion is a common source of greenwashing risk.
“This product’s packaging is made from 80% recycled materials.” (product-level claim)
“We are a sustainable company.” (company-level claim based on one product initiative)
Framework: ISO 14021, UK Green Claims Code
Why it matters
Under EU 2024/825, future environmental commitments require clear, verifiable targets with independent verification pathways. Aspirational language without a plan is a compliance risk.
“We commit to reducing Scope 1 and 2 emissions by 50% by 2030, with annual progress reports verified by [third party].”
“We are working towards a more sustainable future.”
Framework: EU 2024/825, CSRD/ESRS, SBTi Corporate Net-Zero Standard
Note: Under the EU Omnibus Directive (EU 2026/470), mandatory CSRD reporting applies only to companies with more than 1,000 employees and more than €450 million net annual turnover. Companies below these thresholds are exempt but may face voluntary reporting expectations from investors and value chain partners.
Why it matters
EU Directive 2024/825 explicitly prohibits claims of climate neutrality, carbon neutrality, or net zero that are based solely on carbon offsetting. This applies to product claims and corporate claims alike.
“We are reducing absolute emissions by 40% by 2030. Residual emissions are offset through Gold Standard projects while we work toward full decarbonisation.”
“Carbon neutral through certified offset programmes.”
Framework: EU 2024/825, CSDDD, GHG Protocol
Adopted as EU Directive 2024/1760 and amended by the Omnibus Directive (EU) 2026/470, the CSDDD requires very large companies to identify, prevent, mitigate and account for adverse human rights and environmental impacts across their own operations, subsidiaries and value chains.
Post-Omnibus, EU companies with more than 5,000 employees and more than €1.5 billion net worldwide turnover; non-EU companies with more than €1.5 billion EU turnover. Obligations apply from 26 July 2029. Companies below these thresholds are out of scope.
Board-level oversight, supplier codes of conduct, risk-based due-diligence processes, a climate transition plan aligned with 1.5°C, and meaningful engagement with affected stakeholders.
For sustainability communication, CSDDD raises the bar in four concrete ways: mission and purpose statements must explicitly commit to human rights and environmental due diligence; governance pages must name a board or executive-level body responsible for due-diligence oversight; supplier codes of conduct must be published and cover human rights and environmental standards; and stakeholder engagement must be structured, ongoing and documented — not anecdotal.
Key dates: adopted June 2024 · amended by the Omnibus Directive (EU) 2026/470, in force 18 March 2026 · obligations apply from 26 July 2029 for companies above the 5,000 employee and €1.5 billion turnover thresholds. For companies below scope, these remain best-practice expectations rather than legal obligations.
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