Greenwashing: CSRD and EU Consumer Law for Companies

In this lecture, learners are introduced to the core concepts of greenwashing as defined under EU law. We begin with an overview of what counts as a misleading environmental claim under the UCPD, explaining the principles regulators use to assess whether a statement gives consumers the wrong impression.

The lecture then breaks down the three main categories of misleading practices:

• Misleading actions — claims that exaggerate, overstate, or create an impression of strong environmental performance without proof.
• Misleading omissions — when important information is hidden or unclear, leading consumers to believe a product is greener than it is.
• Vague environmental claims — broad terms like “eco-friendly” or “climate friendly” that lack specific meaning unless backed by recognised evidence.

This section gives learners a practical understanding of how and why environmental claims become misleading, forming the basis for the more advanced content that follows.

In this lecture, learners explore the types of environmental claims that regulators consider highly problematic under EU law. We begin by explaining why vague environmental terms — such as “eco-friendly,” “green product,” or “environmentally safe” — are no longer allowed unless companies can demonstrate recognised, excellent environmental performance.

We then examine high-risk claims, including carbon neutrality statements, recyclability and circularity claims, and other broad assertions that frequently mislead consumers. The lecture highlights why these claims attract enforcement action, what evidence is required to justify them, and when companies must avoid using them altogether.

This section provides learners with practical insight into which claims pose the highest compliance risks and how to identify them quickly in real-world marketing.

In this lecture, learners are introduced to the Empowering Consumers for the Green Transition Directive (EmpCo) and its major impact on environmental marketing in the EU. We review the agenda for this section and then explain the new bans on generic environmental claims, one of the most important changes introduced by the directive.

Learners will understand:

• What counts as a generic or vague claim, such as “eco-friendly,” “green,” or “sustainable choice.”
• Why these claims are no longer allowed unless a company can prove recognised, excellent environmental performance.
• Real examples of claims that fall under the ban.
• When a claim can still be used — and what evidence is required to justify it.

This section gives learners the tools to recognise and avoid non-compliant environmental claims under the new EU rules.

In this lecture, learners explore two major areas of the 2024 EmpCo Directive:
(1) new rules on durability, repairability, and performance claims, and
(2) stricter requirements for sustainability labels.

We begin by explaining how EmpCo bans vague or exaggerated statements about product durability, ease of repair, or environmental performance unless they can be fully proven. Learners see practical examples of claims that are now banned or considered misleading, highlighting the need for accurate, realistic product information supported by evidence.

The lecture then examines the new rules for sustainability labels and logos. Companies can no longer use self-made green badges or unverified eco-labels. Only labels based on recognised certification schemes or issued by public authorities are allowed. Examples of non-compliant practices — such as invented “eco leaf” logos or labels with no independent review — help learners identify risks quickly.

This section gives learners a practical understanding of how EmpCo reshapes product claims and sustainability labelling in the EU.

In this lecture, learners receive an introduction to the Green Claims Directive (GCD) — the EU’s forthcoming framework for harmonised, evidence-based environmental claims. We outline the structure of this section and then explain the scope and application of the proposed directive.

Learners will understand:

• Which types of claims the GCD would regulate, including CO₂ footprint claims, “made from recycled materials,” “biodegradable packaging,” and environmental labels or badges.
• That the directive applies to voluntary environmental claims, regardless of whether companies are based inside or outside the EU.
• Which sectors are covered and which limited exceptions apply.

This section sets the stage for the deeper requirements that follow, including scientific substantiation, communication rules, and independent third-party verification.

In this lecture, learners explore the three core pillars of the proposed Green Claims Directive: substantiation, communication, and independent verification of environmental claims.

We begin with the substantiation requirements, explaining how companies would need to rely on scientific evidence, life-cycle assessments, and reliable, up-to-date data to prove the accuracy of any environmental claim. A practical example illustrates what information companies must provide to justify a CO₂ footprint reduction claim.

Next, we examine the rules for communicating claims. Learners see how the GCD would require clear wording, specificity about which part of the product the claim refers to, transparency through supporting information, and an avoidance of exaggerated or overly broad statements.

Finally, we cover the requirement for third-party verification. Under the proposal, companies would need an independent verifier to review their evidence and issue a certificate of conformity before claims can be used, along with ongoing documentation obligations.

This section equips learners with a practical understanding of what companies would need to do to meet future EU standards for credible, science-based environmental claims.

In this lecture, we begin Section 5 of the course, where learners discover how companies can build a robust internal compliance framework to avoid greenwashing risks and meet EU regulatory expectations. The agenda for this section introduces the five key components of an effective governance system: internal approval processes, substantiation documentation, alignment with CSRD/ESRS, best practices, and enforcement considerations.

We then focus on internal governance, explaining why companies need a clear, structured process for creating, reviewing, and approving environmental claims. Learners will see how different teams — marketing, sustainability, legal/compliance, quality, and management — must work together to ensure claims are accurate, evidence-based, and consistent with EU rules.

This section provides a practical foundation for companies to organise their internal responsibilities and prevent vague, unproven, or misleading environmental claims from reaching the market.

In this lecture, learners will understand the core requirement behind all EU anti-greenwashing rules: every environmental claim must be backed by a complete and verifiable substantiation file. We explain what this file is, why it is essential for compliance, and how companies must organise evidence to prove that each claim is accurate, up to date, and not misleading.

The lecture walks through a practical checklist of the documentation that should be included — such as scientific measurements, supplier information, certification reports, life-cycle assessment data, and internal approvals. To make the concept concrete, we use the example of a “50% recycled plastic” bottle claim and break down exactly which documents regulators expect companies to maintain.

This segment equips learners with a clear, actionable framework for building substantiation files that meet EU requirements and withstand scrutiny from authorities, competitors, or consumer organisations.

This section of the course explains how companies must ensure that all environmental and sustainability claims are fully aligned with their official disclosures under the CSRD, ESRS, and the EU Taxonomy. Learners will understand why inconsistent communication—where marketing promises something that reporting data cannot support—creates significant legal and reputational risks. We walk through key alignment requirements, including CO₂ reduction claims, circularity statements, transition plans, and references to “green activities,” showing how mismatches between marketing and mandated reports can lead directly to enforcement actions.

The section then introduces practical best practices for minimising greenwashing risks. Learners receive a concise yet highly effective compliance checklist to apply before publishing any claim, covering clarity, specificity, evidence, internal approval, and consistency with corporate disclosures. We also highlight high-risk sectors such as fashion, cosmetics, food and beverages, electronics, automotive, and packaging—industries where vague or exaggerated sustainability claims frequently lead to regulatory scrutiny.

Finally, we provide a clear overview of how greenwashing rules are enforced across the EU. Learners will see how competition authorities, consumer organisations, courts, and even competitors can challenge misleading claims. The lecture outlines the potential consequences of non-compliance, including cease-and-desist orders, fines, mandatory correction statements, withdrawal of claims, litigation risks, and long-term reputational damage. This section underscores why rigorous internal controls and accurate, evidence-based communication are essential for any company operating in the EU sustainability landscape.

In the closing section of this course, we wrap up the key insights you have gained about the EU’s rapidly evolving anti-greenwashing framework. You will revisit the essential concepts covered throughout the programme, including why greenwashing has become an EU enforcement priority, the core legal architecture governing environmental claims, what constitutes misleading communication, the new obligations introduced under EmpCo, and the foundational compliance operations companies must implement.

We then move to the practical next steps: how to turn this knowledge into action within your own organisation. Learners are encouraged to begin reviewing their environmental claims, evaluate existing substantiation files, and apply the tools and checklists provided during the course to ensure their communication practices are transparent, accurate, and legally compliant.

The closing segment also includes a concise summary of what you have learnt, reinforcing the course’s key takeaways and showing how these rules contribute to fairer markets, more credible sustainability communication, and stronger consumer trust across the EU.