Greenwashing is not a problem of bad intentions. Most of the examples below come from companies with genuine sustainability programmes — the failures are in how claims are communicated, not in whether effort was made. That is exactly what makes ECGT challenging: the directive does not ask whether you are doing good work. It asks whether your claims accurately represent that work, in language that consumers can verify.
Here are the most instructive recent examples, organised by sector, with analysis of what went wrong and how it maps to current EU rules. Check whether your site has similar patterns.
Fashion and Apparel
H&M — Conscious Collection (Sweden, 2022–2025)
H&M's Conscious Collection was the most litigated fashion greenwashing case of the decade. The core issue: items in the collection were marketed as more sustainable based on a Higg Materials Sustainability Index score that the Norwegian Consumer Authority and a subsequent academic review found to be misleading. Some "sustainable" garments scored worse on environmental metrics than standard alternatives.
Under ECGT, this case illustrates the comparative claim problem. The claim implied a measurable environmental advantage. The underlying methodology was contested and not transparently disclosed to consumers. H&M has since suspended the Higg MSI scores, but the pattern of "certified as sustainable by our own methodology" remains common across fast fashion.
ECGT violation type: Unsubstantiated comparative claim. The claim's basis — the Higg MSI — did not meet the independence and methodology transparency requirements now required.
Zara — Join Life (Spain, 2024)
Zara's Join Life range used "sustainable fabric" claims on items containing a small percentage of recycled or organic material. A 10% recycled polyester content does not substantiate a claim that the item is "made with sustainable fabrics" without clear disclosure of the scope limitation. The Spanish CNMC began an investigation in late 2024; the range's labelling was revised in early 2025 before ECGT took effect.
The fix was straightforward: change "sustainable fabrics" to "contains X% recycled polyester" — a specific claim that is accurate and unambiguous.
Food and Beverage
Oatly — Carbon Footprint Claims (UK/EU, 2022–2025)
Oatly's "carbon footprint" labelling was challenged by a UK ASA ruling that found the CO₂e figures on pack were based on a methodology not independently verified to a recognised standard. The company's claim that oat milk is "better for the planet" than dairy was upheld in general terms but the specific footprint figures were not. Oatly subsequently revised the labelling and the underlying LCA methodology.
This is an instructive case because the substantive claim — oat milk does have a lower carbon footprint than cow's milk — is broadly true. The problem was the precision of specific figures without a methodology that regulators could independently verify. ECGT's substantiation requirement would require the same LCA standard going forward.
Danone — Evian "Carbon Neutral" (France, 2023)
Evian's "carbon neutral" certification was based on carbon offsets that offset 100% of the product's lifecycle emissions. The French DGCCRF found the claim misleading because it implied the product had no net environmental impact, when in reality it continued to emit carbon — the neutrality was purchased, not achieved through reduction. Under ECGT, "carbon neutral" based on offsetting alone is one of the explicitly banned claim types.
The corrected approach: disclose the offset mechanism explicitly, quantify the remaining emissions, and present a reduction roadmap. "Our emissions have been offset via verified carbon credits; we are committed to reducing absolute emissions 30% by 2028 per our published transition plan" is a compliant formulation.
Energy
Repsol — "Net Zero" Advertising (Spain, 2023)
Repsol faced investigation from the Spanish regulator over "net zero by 2050" advertising that did not specify what would and would not be included in scope. Scope 3 emissions — those generated when customers burn the fuel Repsol sells — account for 85%+ of an oil company's total emissions. A net-zero claim that excludes Scope 3 covers less than 15% of actual impact.
Under ECGT, this is a future commitment claim without a credible, detailed plan. The claim also implicates Article 6's prohibition on misleading claims about environmental impact. Repsol revised its communications to explicitly scope the commitment and link to a detailed transition plan — though environmental groups continue to contest whether the plan is credible.
E.ON — Green Energy Products (Germany, 2024)
E.ON's "100% green energy" product labelling was investigated by the German Wettbewerbszentrale for failing to disclose that "green" referred to the procurement of renewable energy certificates (RECs), not to the physical electrons delivered to customers — which are indistinguishable from grid electricity in practice. The legal finding: the claim was not false but was misleading by omission. The fix required disclosing the REC mechanism in close proximity to the claim.
Finance and ESG Investing
DWS — ESG Fund Greenwashing (Germany, 2022–2025)
DWS, Deutsche Bank's asset management arm, settled with US and German regulators over claims that a large portion of its assets were "ESG integrated" when the internal processes described did not match the public claims. The SEC settlement was $19M; the German BaFin investigation is ongoing. This case established that ESG marketing claims must accurately reflect actual investment processes, not aspirational targets.
Under ECGT (which covers financial services marketing to EU consumers), a fund marketed as "sustainable" or "ESG-focused" must have substantiation that the underlying investment process meets those characterisations. SFDR (Sustainable Finance Disclosure Regulation) adds a parallel layer of requirements.
BlackRock — ESG Claims Scaling Back (Global, 2023–2025)
BlackRock's systematic reduction of ESG claims in its marketing from 2023 onwards is the clearest corporate acknowledgment that broad sustainability claims without adequate substantiation create legal risk. The company replaced generic ESG messaging with more specific, fund-by-fund characterisations backed by explicit methodology disclosure. This is the ECGT-compliant direction of travel for the industry.
Technology
Microsoft — "Carbon Negative by 2030" (Global, 2023–2025)
Microsoft's carbon negative commitment is generally considered credible — they have published detailed transition plans and have invested heavily in direct air capture. What drew scrutiny was a 2024 annual report showing Scope 3 emissions had increased significantly due to AI infrastructure buildout, calling into question the trajectory toward the 2030 target.
The ECGT lesson: future commitment claims must have credible, public plans with interim milestones. When actual performance diverges from the claimed trajectory, the claim may become retrospectively non-compliant. Microsoft's response — publishing updated projections and revised interim targets — is the model for handling this situation.
Apple — "Carbon Neutral Apple Watch" (Global, 2024)
Apple launched the Apple Watch Series 9 with "carbon neutral" certification under its own Apple 2030 programme. The certification was challenged by environmental groups who argued the offset-heavy methodology and generous Scope 3 exclusions meant the claim did not accurately reflect the product's environmental impact. Under ECGT, a company-internal certification scheme must meet independence and methodology requirements — a brand-owned certification may not qualify.
Cosmetics and Beauty
L'Oréal — "Waterless" Claims (EU, 2023–2025)
L'Oréal's "waterless beauty" campaign implied significant environmental benefit from eliminating water from formulations. Norwegian and Dutch regulators found the implied environmental benefit was overstated — removing water from a formulation has a minor net environmental impact relative to the product's full lifecycle, and the claim did not disclose this scope limitation.
The cosmetics greenwashing sector more broadly faces a specific challenge: "natural" ingredients do not inherently have a lower environmental impact than synthetic alternatives, yet "natural" and "nature-derived" claims are ubiquitous. Under ECGT, using "natural" to imply environmental benefit without substantiation is non-compliant.
Travel and Aviation
KLM — "Fly Responsibly" (Netherlands, 2024)
KLM's "Fly Responsibly" campaign was found to be misleading by a Dutch court in 2024 — the first time a court, rather than a regulator, directly ruled on airline greenwashing under pre-ECGT consumer protection law. The court found the campaign created a false impression that aviation could be sustainable in its current form, when the airline's own climate plans showed emissions would not decrease in line with Paris Agreement targets.
Under ECGT, this type of sector-level sustainability positioning — "we are part of the solution" messaging without specific, substantiated claims — is precisely what the directive targets. The ruling is widely expected to influence how national courts interpret ECGT's requirements for future commitment claims in inherently high-emissions sectors.
Lufthansa — Sustainable Aviation Fuel Offset Offer (Germany, 2023)
Lufthansa's offer to allow passengers to "offset" flight emissions by contributing to sustainable aviation fuel (SAF) investment was investigated by German authorities for implying that the offset mechanism rendered flights carbon neutral. The technical reality — SAF reduces emissions relative to conventional jet fuel but does not eliminate them — was not clearly communicated. The offer was revised to state percentage emissions reduction rather than neutrality.
Cross-Sector Pattern: What ECGT Changes
Reading across all these sectors, the pattern is consistent. The claims that create risk are not lies — they are truths told incompletely. "Carbon neutral" is true if you accept offset accounting. "Sustainable fabric" is true if 10% recycled content counts. "Fly responsibly" is true if responsibility means buying SAF offsets rather than not flying.
ECGT's intervention is to require that the full truth — including the methodology, the scope, the limitations — is communicated with the same prominence as the headline claim. That is a significant change in how sustainability marketing has worked for the past decade.
The sustainability claims do/don't guide translates these sector examples into actionable copy rules. The free scanner checks whether your site currently has claims matching these non-compliant patterns.