How to Talk About Your ESG Progress Without Greenwashing

You have started tracking emissions, installed LED lighting, reduced waste, written policies. Now you want to say so — on the website, in proposals, on packaging.

The wording matters. Regulators in the EU, the UK, and the US are acting against vague or unsubstantiated environmental claims, and the rules reach suppliers of every size. Before writing a claim, establish whether it passes the test below.

Regulatory references checked 14 September 2026. Verify the current status of any instrument before relying on it.

The regulatory position

EU Empowering Consumers Directive (2024/825)

Adopted in February 2024; member states apply it from 27 September 2026.

• Generic claims banned. "Eco-friendly", "green", "environmentally friendly", "natural", and similar cannot be used without demonstrated recognized excellent environmental performance relevant to the claim.
• "Carbon neutral" via offsets banned. A product or company cannot be described as having a neutral, reduced, or positive environmental impact on the basis of carbon offsetting.
• Sustainability labels must be certified. No self-created "green" badges; labels must rest on an official certification scheme.

Penalties follow the Unfair Commercial Practices Directive: fines of up to 4% of annual turnover.

EU Green Claims Directive (proposal)

The 2023 proposal would have required life-cycle-based substantiation and independent verification of environmental claims before use. On 20 June 2025 the European Commission announced its intention to withdraw the proposal; its formal status has remained unclear since. Do not plan around it. The Empowering Consumers Directive above is the operative EU rule.

UK Green Claims Code

The Competition and Markets Authority has enforced its Green Claims Code since 2021. Six principles: claims must be truthful, clear, not omit important information, compare fairly, be substantiated, and consider the full life cycle. The CMA has investigated and acted against companies in fashion and FMCG over misleading "sustainability" ranges.

US FTC Green Guides

The Federal Trade Commission's Green Guides require environmental claims to be truthful, substantiated, and not misleading. Updates addressing carbon offsets, "recyclable", and "net zero" have been under review. Violations can carry fines per violation.

Five claims that cause trouble

1. "We are a sustainable supplier"

Why. "Sustainable" is undefined. Compared to what, by which measure. It is the generic claim regulators target.

Instead. "We reduced energy consumption by 12% in 2025 through equipment upgrades and operational changes."

2. "Carbon neutral" or "climate neutral"

Why. In the EU, neutrality based on offsets cannot be claimed. Elsewhere, the term implies zero impact, which is almost never true for a manufacturing or logistics supplier.

Instead. "Our Scope 1 and 2 emissions were 245 metric tons CO2e in 2025, down 18% from 2024. We are reducing further through energy efficiency and renewable electricity procurement."

3. "Eco-friendly packaging" or "green materials"

Why. "Eco-friendly" is among the most commonly flagged terms. Friendly compared to what, over which life-cycle stage.

Instead. "Our packaging contains 70% post-consumer recycled content." Or: "Our packaging is recyclable in standard municipal recycling streams in the EU."

4. "We are committed to sustainability"

Why. Not technically a claim, and therefore common. Regulators and customers read it as empty without data behind it. It does not differentiate.

Instead. "We track energy, water, and waste annually. Our environmental policy covers emissions reduction, waste diversion, and supplier assessment. The latest data is below."

5. "Net zero by 2030"

Why. Net zero targets require a science-based pathway, interim milestones, and defined scope. A target without a credible plan is a challengeable claim, especially if it relies on offsets.

Instead. "We have set a target to reduce Scope 1 and 2 emissions by 42% by 2030 against a 2023 baseline. The plan includes renewable electricity, fleet electrification, and process efficiency."

The rule: data, not labels

Every defensible environmental claim follows one pattern:

Specific metric + time period + scope + methodology on request

Instead of "green", "clean", "sustainable", or "carbon neutral", report what was measured, what the figure was, how it changed, and what comes next.

This is what ESG questionnaires ask for, and it is what makes marketing defensible. The data gathered for EcoVadis, CDP, or a customer questionnaire is the same data that supports a claim.

B2B and B2C

The Empowering Consumers Directive targets B2C claims primarily, but a misleading B2B claim can fall under unfair commercial practices. Procurement teams are increasingly trained to identify greenwashing in supplier proposals. Vague claims do not win contracts.

Three questions before any claim

1. Can I put a number on it? If yes, use the number instead of the adjective. If no, do not make the claim.
2. Can I show the evidence if challenged? Utility bills, waste transfer records, certificates, calculation methods. If evidence cannot be produced in reasonable time, the claim is unsubstantiated.
3. Does the claim cover the whole picture? "Made with renewable energy" while shipping is carbon-intensive is misleading by omission. State what the claim does and does not cover.

What can be claimed

The pattern: third-party verification, specific figures, defined scope, clear timeframe.

Early in the process

Most suppliers do not have an EcoVadis Gold or a zero-waste facility. Honest progress is more credible than a premature claim:

• "We started tracking our carbon emissions in 2025."
• "We are building our ESG data infrastructure to respond to customer assessments."
• "Our first sustainability data report covers Scope 1 and 2 emissions, workforce metrics, and core policies."

Customers and regulators do not expect perfection from an SME. They expect honesty and a credible direction. If nothing has been measured yet, the free carbon calculator produces a first Scope 1 and 2 estimate from energy bills. A real number beats any adjective.

In short

The safest marketing strategy for ESG progress is also the most effective: specific numbers, verifiable credentials, and honest acknowledgment of what is still improving. If the data is tracked properly, the marketing material already exists.

Official References

• Directive (EU) 2024/825 — empowering consumers for the green transition
• UK CMA — Green Claims Code
• FTC Green Guides
• Latham & Watkins — Commission's intention to withdraw the Green Claims Directive

Related Guides

• ESG Policy Template for SMEs: What Small Companies Actually Need
• Supplier Code of Conduct Template: How to Create One in a Day
• GHG Reporting for Suppliers: Scope 1, 2 and 3 Explained and What to Report