Greenwashing examples

The clearest official greenwashing examples are the ones the EU and the FTC wrote themselves

Direct answer. The examples on this page are wording that regulators wrote into the law or into the guides: the practices Directive (EU) 2024/825 inserts into Annex I of Directive 2005/29/EC, the examples in that directive’s recitals, and the Example paragraphs in the US FTC Green Guides, 16 CFR Part 260. EMPCO quotes are the English Official Journal of Directive (EU) 2024/825. FTC quotes are the eCFR full text of title 16 part 260 for the version dated 1 January 2026, whose source note is 77 FR 62124, Oct. 11, 2012, unless otherwise noted. This page names no company, no lawsuit, and no enforcement case. It is not legal advice.

Green Claims Guard (Shopify App Store · Write a review): “Scan green marketing wording, review possible issues, and export dated evidence records for Shopify catalog and content review.” It does not certify claims as compliant.

Related: CLPLens — Hazard pictograms on the product page, not only the parcel.

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Checklist

Which text this page quotes

Directive (EU) 2024/825 quotes are the English Official Journal (L series, 2024/825). A Slovenian corrigendum exists as CELEX 32024L0825R(01), OJ of 20 December 2024. The expression available for that corrigendum when checked was Slovenian. This page quotes the English Official Journal and did not find an English corrigendum of the annex points or of Article 4.

The annex prints an opening quotation mark before the point number, because the points are inserted into Annex I. Point 4a’s text cell also begins with an opening quotation mark. The closing quotation mark for points 4a, 4b and 4c sits at the end of 4c. The words below follow that printing.

Annex points, as written

Point 2a: “Displaying a sustainability label that is not based on a certification scheme or not established by public authorities.”

Point 4a: “Making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim.”

Point 4b: “Making an environmental claim about the entire product or the trader’s entire business when it concerns only a certain aspect of the product or a specific activity of the trader’s business.”

Point 4c: “Claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.”

Point 10a: “Presenting requirements imposed by law on all products within the relevant product category on the Union market as a distinctive feature of the trader’s offer.”

The wider directive is the EMPCO summary. Generic claims are the generic-claims page. Offsets are carbon-neutral and offset claims. Whole-product wording is whole product versus one part. Labels are sustainability labels and own badges. The status of the later Green Claims proposal is that status page.

Recital examples

Recital 9 includes: “Examples of generic environmental claims include ‘environmentally friendly’, ‘eco-friendly’, ‘green’, ‘nature’s friend’, ‘ecological’, ‘environmentally correct’, ‘climate friendly’, ‘gentle on the environment’, ‘carbon friendly’, ‘ energy efficient’, ‘biodegradable’, ‘biobased’ or similar statements that suggest or create the impression of excellent environmental performance.” The space inside the quotation marks before “energy efficient” is printed that way in the Official Journal HTML.

The same recital: “For example, the claim ‘climate-friendly packaging’ would be a generic claim, whilst claiming that ‘100 % of energy used to produce this packaging comes from renewable sources’ would be a specific claim, which would not fall under this prohibition, without prejudice to other provisions of Directive 2005/29/EC remaining applicable to those specific claims.”

Recital 11: “That ban would apply, for example, when a product is marketed as ‘made with recycled material’ giving the impression that the entire product is made of recycled material, when in fact only the packaging is made of recycled material.” Recycled-content percent wording on a store is the recycled-content percent guide.

Recital 12: “Examples of such claims are ‘climate neutral’, ‘CO2 neutral certified’, ‘carbon positive’, ‘climate net zero’, ‘climate compensated’, ‘reduced climate impact’ and ‘limited CO2 footprint’.” In the Official Journal, the “2” is a subscript.

Recital 15: “This prohibition should apply, for example, where a trader advertises a given product as not including a specific chemical substance when that substance is already forbidden by law for all products within that product category in the Union.”

Article 4, as written

Article 4 is titled “Transposition.” Article 4(1): “By 27 March 2026, Member States shall adopt and publish the measures necessary to comply with this Directive. They shall immediately inform the Commission thereof. They shall apply those measures from 27 September 2026. When Member States adopt those measures, they shall contain a reference to this Directive or shall be accompanied by such reference on the occasion of their official publication. The methods of making such reference shall be laid down by Member States.”

FTC Green Guides examples

§ 260.1(d): “The examples provide the Commission’s views on how reasonable consumers likely interpret certain claims.” The sections below are linked on eCFR. The Green Guides summary is the longer map of Part 260. Compostable and biodegradable wording is that guide.

§ 260.4 Example 1: “The brand name ‘Eco-friendly’ likely conveys that the product has far-reaching environmental benefits and may convey that the product has no negative environmental impact. Because it is highly unlikely that the marketer can substantiate these claims, the use of such a brand name is deceptive. A claim, such as ‘Eco-friendly: made with recycled materials,’ would not be deceptive if: (1) The statement ‘made with recycled materials’ is clear and prominent; (2) the marketer can substantiate that the entire product or package, excluding minor, incidental components, is made from recycled material; (3) making the product with recycled materials makes the product more environmentally beneficial overall; and (4) the advertisement’s context does not imply other deceptive claims.”

§ 260.6 Example 1: “An advertisement for paint features a ‘GreenLogo’ seal and the statement ‘GreenLogo for Environmental Excellence.’ This advertisement likely conveys that: (1) the GreenLogo seal is awarded by an independent, third-party certifier with appropriate expertise in evaluating the environmental attributes of paint; and (2) the product has far-reaching environmental benefits. If the paint manufacturer awarded the seal to its own product, and no independent, third-party certifier objectively evaluated the paint using independent standards, the claim would be deceptive. The claim would not be deceptive if the marketer accompanied the seal with clear and prominent language: (1) indicating that the marketer awarded the GreenLogo seal to its own product; and (2) clearly conveying that the award refers only to specific and limited benefits.”

§ 260.12 Example 1: “A packaged product is labeled with an unqualified claim, ‘recyclable.’ It is unclear from the type of product and other context whether the claim refers to the product or its package. The unqualified claim likely conveys that both the product and its packaging, except for minor, incidental components, can be recycled. Unless the manufacturer has substantiation for both messages, it should clearly and prominently qualify the claim to indicate which portions are recyclable.”

§ 260.13 Example 1: “A manufacturer collects spilled raw material and scraps from the original manufacturing process. After a minimal amount of reprocessing, the manufacturer combines the spills and scraps with virgin material for use in production of the same product. A recycled content claim is deceptive since the spills and scraps are normally reused by industry within the original manufacturing process and would not normally have entered the waste stream.”

Example wording, the official reason, and the source

Each row is a phrase from a quotation on this page. The middle column uses the official text’s own reason, not a paraphrase of a case.

Example wording, why the official text treats it as a problem, and the source
Example wording Why the official text treats it as a problem Source
“a sustainability label that is not based on a certification scheme or not established by public authorities” “Displaying a sustainability label that is not based on a certification scheme or not established by public authorities.” Directive (EU) 2024/825, Annex, point 2a
‘eco-friendly’ “Examples of generic environmental claims include ‘environmentally friendly’, ‘eco-friendly’” and the point: “Making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim.” Recital 9 and Annex point 4a
‘climate-friendly packaging’ “the claim ‘climate-friendly packaging’ would be a generic claim” Recital 9
‘made with recycled material’ “giving the impression that the entire product is made of recycled material, when in fact only the packaging is made of recycled material.” Point 4b: “Making an environmental claim about the entire product or the trader’s entire business when it concerns only a certain aspect of the product or a specific activity of the trader’s business.” Recital 11 and Annex point 4b
‘climate neutral’ “Examples of such claims are ‘climate neutral’” and point 4c: “Claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.” Recital 12 and Annex point 4c
“advertises a given product as not including a specific chemical substance when that substance is already forbidden by law” “This prohibition should apply, for example, where a trader advertises a given product as not including a specific chemical substance when that substance is already forbidden by law for all products within that product category in the Union.” Point 10a: “Presenting requirements imposed by law on all products within the relevant product category on the Union market as a distinctive feature of the trader’s offer.” Recital 15 and Annex point 10a
Brand name “Eco-friendly” “Because it is highly unlikely that the marketer can substantiate these claims, the use of such a brand name is deceptive.” 16 CFR § 260.4 Example 1
“GreenLogo for Environmental Excellence” “If the paint manufacturer awarded the seal to its own product, and no independent, third-party certifier objectively evaluated the paint using independent standards, the claim would be deceptive.” 16 CFR § 260.6 Example 1
Unqualified “recyclable” “The unqualified claim likely conveys that both the product and its packaging, except for minor, incidental components, can be recycled. Unless the manufacturer has substantiation for both messages, it should clearly and prominently qualify the claim to indicate which portions are recyclable.” 16 CFR § 260.12 Example 1
“spilled raw material and scraps from the original manufacturing process” “A recycled content claim is deceptive since the spills and scraps are normally reused by industry within the original manufacturing process and would not normally have entered the waste stream.” 16 CFR § 260.13 Example 1

Where this wording usually appears in a Shopify store

Practical, not a legal test. Wording of this kind usually shows up in product titles, product descriptions, badges, collection copy, and blog posts. That is a description of store surfaces, not a rule about which surface the directive or the Green Guides name.

What this page is not

Related pages

Not legal advice. Confirm Directive (EU) 2024/825 and 16 CFR Part 260 before you treat a phrase as covered. EMPCO quotes are the English Official Journal. FTC quotes are the eCFR text described above. The app scans green marketing wording, reviews possible issues, and exports dated evidence records. It does not certify claims as compliant.