Avoiding greenwashing: Moving from marketable spin to measurable impact
If your business was challenged to prove every sustainability statement you’ve made, could you back it up with hard evidence?
Sustainability isn’t a PR exercise, yet too many companies still treat it like one. What’s presented as proof of progress is often more marketing than measurement. Sometimes that’s intentional, but more often it’s inadvertent, driven by enthusiasm without a full understanding of the obligations, the scope, or the risks. The result is the same: businesses open themselves up to regulatory penalties, reputational damage, and a loss of trust that’s hard to recover from.
Inadvertent greenwashing is far more common than many leaders realise. A lot of it stems from leaving ESG communications in the hands of marketing or PR teams without giving them the right data, training, or cross-departmental input. It’s not enough to say you’re “decarbonising” if you’re only tracking Scopes 1 and 2, or to declare yourself “net zero” without tackling Scope 3 and the wider sustainability agenda. True sustainability performance covers environmental, social, and governance factors, and that requires leadership ownership, not just a good narrative.
This isn’t a minor compliance detail. The Competition and Markets Authority (CMA) has made greenwashing a key enforcement priority, with new powers to issue direct fines of up to 10% of global turnover for breaches of the Green Claims Code. The rules apply to all forms of environmental messaging — advertising, labelling, packaging, online content, and sustainability reports — and they demand accuracy, evidence, and transparency.
Understanding greenwashing
According to the United Nations, ““Greenwashing misleads the public into believing that a company or other entity is doing more to protect the environment than it actually is.” This does not always involve outright falsehoods. Often, it takes the form of selective language, vague descriptions, or visual cues that create a false impression of sustainability.
The Green Claims Code sets clear expectations for all forms of environmental messaging, including advertising, labelling, packaging, online content, and sustainability reports. It demands:
Truthfulness and accuracy: All environmental claims must be truthful and not give a false impression, whether through wording, images or branding.
Clarity and unambiguity: Claims must be clear and easy to understand. They should avoid vague terms like “eco-friendly” or “green” unless clearly defined.
Full picture representation: Claims must not omit or hide important information that could affect how they are interpreted. This includes any negative impacts or trade-offs.
Evidence-based: Businesses must be able to back up all claims with robust, credible, and up-to-date evidence. This includes data, certifications, and life cycle assessments where appropriate.
Fair and meaningful comparisons: If a comparison is made with other products or businesses, it must be fair, meaningful, and based on equivalent information.
Consideration of the product lifecycle: Claims should reflect the overall environmental impact across the full life cycle of the product or service, not just a single part of it.
Many businesses unintentionally fall into the trap of greenwashing by using broad or unqualified language in their marketing. Claims such as “eco-friendly,” “sustainable,” or “carbon neutral” are often made without proper explanation or supporting data. In some cases, organisations highlight a single positive feature while ignoring wider environmental impacts. For example, a product might be described as recyclable, yet the manufacturing process behind it generates high levels of emissions. Others may rely on offsetting schemes to claim carbon neutrality, without taking meaningful steps to reduce actual emissions from their operations or supply chains.
Visual branding can also contribute to greenwashing. Using images of nature, such as trees or water, or applying green-coloured packaging, can imply environmental benefit even when none exists. Some businesses focus heavily on future targets, giving the impression of progress while offering little evidence of current action. Others change or update their sustainability goals frequently, creating the illusion of ambition without accountability. These forms of messaging can mislead customers and investors, even if the business has no intention to deceive. Without clear definitions, measurable data and transparency about trade-offs, even well-meaning communications can fall short of the Green Claims Code.
As concerns about greenwashing have come to the fore, we have seen the introduction of new terms to describe misleading behaviour. These include greenhushing, where a company deliberately avoids disclosing its sustainability claims to reduce scrutiny, and greenlighting, where one green initiative is spotlighted to draw attention away from poor practices elsewhere. In addition, green rinsing refers to frequently changing sustainability goals before they are achieved, creating the illusion of progress without real accountability.
The cost of non-compliance
The CMA’s Green Claims Code sets a clear standard for businesses. Environmental claims must be truthful, accurate, clear, and supported by credible evidence. They should reflect the full life cycle impact of a product or service, including trade-offs, and be transparent about any conditions that apply. A review conducted by Which? in July 2025 found that 84% of sustainability claims reviewed failed at least one of these principles, with 62% failing on multiple counts.
Several high profile companies have already been subject to CMA intervention. ASOS, Boohoo, and George at Asda were required to amend the way they marketed their sustainable clothing lines. Unilever was also investigated and asked to review its environmental messaging across product categories. Although no fines have yet been issued under the Green Claims Code, the new legislation now allows the CMA to act without going through the courts. This is expected to accelerate enforcement.
Net Zero scrutiny
One of the most sensitive areas of greenwashing risk involves Net Zero and decarbonisation claims. Many businesses have begun to present themselves as “carbon neutral” or “on the path to Net Zero” while only reporting on Scope 1 and Scope 2 emissions. It is Scope 3 categories that account for the vast majority of a company’s GHG emissions category, covering everything from supply chain activities and product use to waste disposal.
Without measuring Scope 3 emissions, it is not possible to make meaningful or accurate claims about carbon neutrality. Best practice requires that businesses quantify, disclose and actively reduce emissions across all three scopes. Relying on offsetting to cover gaps, without a clear reduction plan, no longer meets public or regulatory expectations.
It is not only the companies themselves that need to take responsibility for compliance. Marketing agencies, PR consultants, branding teams and communications professionals who produce material on behalf of clients are also accountable. Any party involved in creating or approving environmental claims must ensure that content is based on evidence, clearly worded, and free from misleading implications.
Risk management
There are several practical steps that businesses can take to stay compliant and build trust with their stakeholders.
First, be clear about what your claim covers. Whether you are referring to a product, a process or your entire operation, make the boundaries explicit. Second, ensure that Scope 3 emissions are measured and included in your Net Zero strategy. Without this, any claim of carbon neutrality lacks credibility. Third, support all claims with robust and up-to-date evidence. This might include emissions data, third-party certifications, or verified impact assessments. Fourth, avoid using green visuals or language unless it reflects reality. Finally, establish a process to regularly review and update claims as information and regulations evolve.
Trusted partner
Navigating the complexities of sustainability communications is not easy, particularly in a fast-moving regulatory environment. That is where Wylde Connections can help. As specialists in ESG strategy and sustainability reporting, we support organisations to create accurate, compelling and compliant narratives that reflect their genuine progress.
We help clients measure Scope 3 emissions, align with the Green Claims Code, and develop communications that resonate with customers and stakeholders alike. Whether you are preparing your first ESG report or refining a Net Zero message, working with Wylde Connections can reduce your risk of greenwashing and improve the integrity of your brand. Book a Discovery Call today to learn how we can help you achieve your goals.