Greenwashing in Data: Rules and Reality of Environmental Claims

Greenwashing, in data

Claims or advertising that make something look more environmentally friendly than it is are called greenwashing. This page lists, from primary sources, the rules on environmental claims set by public authorities in the EU and Japan, and figures from surveys of actual claims. In a 2020 European Commission study, 53.3% of the environmental claims examined were vague, misleading or unfounded.

This page was compiled by Karatsu Farm & Food as part of the Karatsu Data Bank. It lists only the figures and statements in the sources, without conclusions or evaluations. Whether the claims of individual companies or products are appropriate is not covered. For enforcement cases, company names are not given in the text; they can be found through the linked sources. Quotations from Japanese sources are our translations; the originals prevail.

Item	Content
Entry into force	26 March 2024
Transposition deadline for Member States	27 March 2026
Date of application	27 September 2026 (including products and packaging already on the market)
Annex I point 4a (prohibited in all circumstances)	Generic environmental claims for which the trader cannot demonstrate recognised excellent environmental performance
Annex I point 4c (prohibited in all circumstances)	Claiming, based on offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact (e.g. "climate neutral", "CO2 neutral certified", "carbon positive")
Annex I point 2a (prohibited in all circumstances)	Displaying a sustainability label not based on a certification scheme or not established by public authorities

EU: ban on unsubstantiated environmental claims (from 27 September 2026)

The EU amended the Unfair Commercial Practices Directive through Directive (EU) 2024/825 on empowering consumers for the green transition (ECGT Directive). According to the European Commission's Q&A (European Commission Q&A (September 2026)), the Directive "entered into force on 26 March 2024. Member States had to transpose its provisions by 27 March 2026", and it "shall apply from 27 September 2026", including for products and packaging already on the market.

Practices added to the list prohibited in all circumstances include "making a generic environmental claim for which a trader is not able to demonstrate recognised excellent environmental performance relevant to the claim" (point 4a), "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 4c), and displaying a sustainability label not based on a certification scheme or not established by public authorities (point 2a). The Q&A gives "climate neutral", "CO2 neutral certified" and "carbon positive" as examples under 4c, and notes that claims based on actual reductions over the product's own life cycle are allowed and that 4c does not apply to claims about offsetting at company level.

EU: environmental claims in practice (2020 study)

The European Commission's Q&A (European Commission Q&A (March 2023)) states that, in a 2020 Commission study, "53.3% of the claims examined were vague, misleading or unfounded" and "40% were completely unsubstantiated". It also notes that some 230 "green" labels were identified in the EU, and that this variety was found in itself to undermine consumer trust.

No.	Basic item (our translation)
1	Do not make vague expressions or environmental claims
2	Attach an explanation to the content of the environmental claim
3	Consider the whole life cycle of the product
4	Be able to provide the data and evaluation methods needed to verify the claim, with access to the information
5	Make comparative claims on products or processes appropriately, using LCA, figures and the like

Japan: Ministry of the Environment Environmental Labelling Guidelines (March 2026)

The Ministry of the Environment revised its Environmental Labelling Guidelines on 31 March 2026 (Ministry of the Environment press release). The guidelines (Ministry of the Environment guidelines) are aimed mainly at businesses and business associations making self-declared environmental claims, and also cover claims not directly tied to transactions, such as corporate activities, image advertising and corporate stance. They state that they were revised in March 2026 "in light of international trends in measures against greenwashing" (our translation).

For carbon offset claims, the guidelines say they should preferably follow the six points of the Ministry's offset guidelines, including that offsetting "should not be used to justify not reducing one's own emissions" (our translation). For recycled materials or bioplastics labelled under the mass balance approach, they note that it "does not match the actual blend ratio, and its environmental value is hard to see at a glance compared with actual use" (our translation), so labelling suited to the product is needed.

Item examined	Result
Labels whose environmental benefit is not clear on their face	59 of 139
Labels unclear on scope (product or packaging)	20 of 139
Labels not stating the share of material in figures	29 of 62 labels on materials
Labels not stating the reduction rate in figures	15 of 25 labels on reducing fossil-based plastics

Question	Answer
Share of the material you think is used	"about 50% or more" 73.0% (of which "100%" 33.6%)
Reduction rate you think is meant	"about 50% or more" 80.1% (of which "100%" 50.6%)
Meaning of a label without explanation	"something environmentally friendly, eco" 55.1%
Scope (pencil example)	think the product itself is covered 73.7%

Japan: Consumer Affairs Agency survey of environmental labels (August 2026)

On 20 August 2026 the Consumer Affairs Agency published a report on environmental labels from the viewpoint of the Act against Unjustifiable Premiums and Misleading Representations (Consumer Affairs Agency notice, Consumer Affairs Agency press release). The press release states that labels misleading consumers into thinking a product is significantly more environmentally friendly than it is are a problem as misleading representations under the Act. It collected 139 online environmental labels, interviewed 15 businesses and 3 third-party certification bodies, and surveyed 1,000 consumers (Consumer Affairs Agency survey). It builds on a 2001 report by the Japan Fair Trade Commission on advertising of environmentally friendly products.

Of the 139 labels, 59 did not make their environmental benefit clear on their face, for example with no explanation alongside. One example is a cosmetics box with a label made only of the letters "ECO" and a leaf illustration. Of 62 labels about materials, 29 did not state the share in figures, while 73.0% of consumers assumed the share was "about 50% or more". Of 25 labels about reducing fossil-based plastics, 15 did not state the reduction rate, while 80.1% assumed it was "about 50% or more". In interviews, some businesses said they obtained only third-party labels whose criteria are relatively easy to meet.

Japan: orders on "biodegradable" claims

According to a Ministry of the Environment document (Ministry of the Environment material), in December 2022 a total of 10 companies making "biodegradable" claims (2 selling cutlery, straws, cups and the like; 1 selling fishing goods; 2 selling rubbish and shopping bags; and 5 selling BB pellets for air guns) received orders under the Act against Unjustifiable Premiums and Misleading Representations. The claims at issue suggested that products decompose into water and carbon dioxide through microorganisms in soil or water after use; the document gives BB pellets as an example. In February 2024, one of the five BB pellet companies received an order to pay a surcharge. Individual companies and products can be found in the Consumer Affairs Agency's published materials (e.g. Consumer Affairs Agency order (published 23 December 2022)).

No.	Principle
1	Nature as a whole
2	Avoid and mitigate
3	Holistic actions
4	Aligned with global goals
5	Mainstreaming
6	Collaborative
7	Adaptive
8	Transparent
9	Just
10	Measurable

Claims about nature and biodiversity

In a 2023 report (IUCN (2023)), IUCN set out ten core principles for businesses pursuing nature positive goals. Principle 2 focuses on avoiding and minimising impacts, aiming for at least no net loss and ideally a net positive impact.

On 6 October 2025, the Nature Positive Initiative announced work on guidance on how to communicate nature positive outcomes (Nature Positive Initiative (October 2025)). It said that "anything related to nature conservation might be branded nature positive, with the potential to drift towards greenwashing", and planned a draft for consultation in early 2026. The Kumamoto Declaration published on 15 July 2026 by participants of the second Global Nature Positive Summit (Kumamoto Declaration) calls for standardised metrics on corporate impacts on nature and consistent approaches to assessment, target-setting and reporting, but does not mention claims or greenwashing.

Claims about "ocean plastic"

In a 2022 briefing (Surfrider Foundation Europe (2022)), the European environmental organisation Surfrider Foundation Europe reviewed corporate claims about plastics and the ocean, and wrote that labels claiming "ocean plastic" give the impression that buying a product cleans up plastic pollution. The challenges of recycling ocean plastic as material are covered in Recycling Ocean Plastic in Data.

FAQ

Q1. What is greenwashing?

The term refers to claims or advertising that make something look more environmentally friendly than it is. Because countries define it differently in law, this page lists the rules on environmental claims set by public authorities in the EU and Japan, and figures from surveys of actual claims.

Q2. Which environmental claims are banned in the EU?

Under Directive (EU) 2024/825, from 27 September 2026 the following are prohibited in all circumstances: generic environmental claims without recognised excellent environmental performance; claims, based on offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact; and sustainability labels not based on a certification scheme or not established by public authorities (European Commission Q&A, September 2026).

Q3. Are there rules on environmental claims in Japan?

The Consumer Affairs Agency states that environmental labels that mislead consumers into thinking a product or service is significantly more environmentally friendly than it actually is are a problem as misleading representations under the Act against Unjustifiable Premiums and Misleading Representations. In March 2026 the Ministry of the Environment revised its Environmental Labelling Guidelines, setting five basic items: no vague claims, attach explanations, consider the whole life cycle, be able to provide verification data, and make comparisons using LCA or figures.

Q4. How often do Japanese environmental labels lack explanation?

In a survey published by the Consumer Affairs Agency in August 2026, 59 of 139 online environmental labels did not make their environmental benefit clear on their face. 29 of 62 labels about materials did not state the share in figures, while 73.0% of consumers surveyed assumed the share was "about 50% or more".

Q5. Are there international guides for claims about nature and biodiversity?

In 2023 IUCN set out ten principles for businesses pursuing nature positive goals, including nature as a whole, avoid and mitigate, transparent and measurable. In October 2025 the Nature Positive Initiative announced work on guidance on how to communicate nature positive outcomes, noting the risk of the term drifting towards greenwashing.

Sources

What this page does not cover

Judgements on whether the claims of individual companies or products are appropriate are not covered. The status of the separate EU proposal on substantiating claims (Green Claims Directive), surcharge amounts in Japan, enforcement figures in other countries such as the UK and Australia, and ESG labelling of financial products are not included because they could not be confirmed in primary sources. Values that could not be confirmed in a primary source are not included.

About this page

Compiled by Hiroaki Kojima (Vice Director, Karatsu Farm & Food) / Contact: info@karatsu-f-f.com (contact form) / Published: October 19, 2026 / Markdown: en/greenwashing-data.md

This page is made together with AI. See this data bank and AI for how.

Related links

▶ Karatsu Data Bank
▶ Recycling Ocean Plastic in Data
▶ Circular Economy in Data
▶ Business and Biodiversity
▶ グリーンウォッシュのデータ（日本語）