Greenwashing Risk Assessment Template (Free 2026)
A greenwashing risk assessment identifies which environmental claims in your marketing carry regulatory and reputational risk under the EU Green Claims Directive (ECGT) and equivalent national laws. This template gives you a structured, repeatable process to score every claim — and fix the high-risk ones before an authority does it for you.
Use this template alongside our automated website scanner for complete coverage: the template handles offline materials and internal review; the scanner handles your live website continuously.
Why Greenwashing Risk Assessment Matters in 2026
Regulators are no longer waiting for consumer complaints. The Dutch ACM, UK CMA, and German Wettbewerbszentrale all run proactive market surveillance — they actively scan brand websites and advertising for non-compliant claims. The ECGT enforcement regime adds administrative fines of up to 4% of annual EU turnover, plus mandatory corrective measures and temporary bans on making new environmental claims.
A risk assessment done before enforcement contact is worth orders of magnitude more than one done after. See our guide on greenwashing penalties by country for the full financial picture.
The 5-Step Risk Assessment Process
Step 1 — Inventory All Environmental Claims
You cannot assess what you have not listed. Compile every environmental claim across all channels:
- Website copy (homepage, product pages, about/sustainability pages)
- Paid advertising (Google Ads, social ads, display)
- Social media bio and posts
- Email marketing templates
- Product packaging and labelling
- Press releases and investor communications
- Trade show and event materials
Pro tip: Run a GreenClaims Scanner first — it will surface all environmental claims on your website automatically, saving several hours of manual inventory for your digital presence.
Step 2 — Classify Each Claim by Type
Claims fall into four categories under ECGT, each with different substantiation requirements:
| Claim Type | Example | Substantiation Required |
|---|---|---|
| General / Vague | "Eco-friendly", "green", "sustainable" | Highest — lifecycle evidence + third-party verification |
| Specific Environmental | "Made with 30% recycled content" | Documentary evidence, verifiable data |
| Comparative | "50% lower emissions than industry average" | Defined comparison basis, same methodology |
| Certification-Based | "Certified carbon neutral by [body]" | Valid certification from accredited body, ECGT-approved scheme |
See our full list of banned green marketing terms under ECGT for terms that are prohibited regardless of substantiation.
Step 3 — Score Each Claim on Risk Dimensions
Apply this scoring matrix to each claim. Score 1 (low risk) to 5 (high risk) on each dimension:
| Dimension | 1 — Low Risk | 3 — Medium Risk | 5 — High Risk |
|---|---|---|---|
| Specificity | Precise, quantified claim with defined scope | Partially qualified | Vague / general ("green", "sustainable") |
| Substantiation | Third-party verified, evidence publicly available | Internal data only, not independently verified | No supporting evidence exists |
| Scope Accuracy | Claim clearly scoped to product/process it applies to | Scope implied but not stated | Claim implies whole company/product when only partial |
| Comparative Basis | No comparison, or comparison fully defined | Comparison implied but vague | "Better than", "lower than" with no defined baseline |
| Certification Status | Valid ECGT-recognised certification, current | Third-party cert but not ECGT-recognised scheme | No certification, or certification expired/self-awarded |
Total risk score: Sum the five dimensions. Interpret as follows:
- 5–10: Low risk — document your evidence and maintain
- 11–17: Medium risk — improve substantiation or qualify the claim
- 18–25: High risk — revise or remove before enforcement contact
Step 4 — Prioritise and Assign Owners
Not all high-risk claims are equally urgent. Prioritise by:
- Visibility: Homepage and above-the-fold claims carry higher regulatory scrutiny than deep product pages
- Revenue association: Claims on your highest-converting pages carry highest reputational and commercial risk if challenged
- Active advertising: Claims in paid media are actively monitored by advertising standards bodies and national consumer protection authorities
For each high-risk claim, assign: a claim owner (usually marketing or legal), a remediation action (revise, remove, substantiate, or certify), and a deadline tied to your next content update cycle.
Step 5 — Document Everything
ECGT requires pre-substantiation — evidence must exist before the claim is made, not assembled after a regulator asks. Create a claim substantiation file for each claim you retain:
- The exact claim text and where it appears
- The evidence supporting it (LCA report, certification certificate, data source)
- The date the evidence was obtained
- The third-party verifier, if applicable
- Review date (claims should be re-verified annually or when the product changes)
See our guide on how to substantiate environmental claims for detailed documentation requirements.
Risk Assessment Template: Downloadable Format
Use this structure in a spreadsheet (Google Sheets or Excel). One row per claim:
| Claim Text | Channel | Page/Location | Claim Type | Specificity (1-5) | Substantiation (1-5) | Scope (1-5) | Comparative (1-5) | Certification (1-5) | Total Score | Risk Level | Action | Owner | Deadline |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| "100% sustainable packaging" | Website | /product/xyz | General | 4 | 3 | 3 | 1 | 4 | 15 | Medium | Add "made from X% recycled material, certified by Y" | Marketing | 2026-04-01 |
Common High-Risk Claims to Watch For
Based on enforcement actions across the EU and UK, these claim patterns consistently score 18–25 on the risk matrix:
- "Carbon neutral" without specifying scope and offsetting methodology (see our carbon neutral claims guide)
- "Climate neutral" — now effectively banned under ECGT as a standalone claim (see alternatives to climate neutral)
- "Eco-friendly" with no qualification
- "Sustainable" applied to the whole company rather than a specific, verified aspect
- Comparative claims ("greener than", "lower carbon than competitors") without naming the comparison and methodology
- Self-awarded labels that look like third-party certifications
Automate the Ongoing Monitoring
A risk assessment is a point-in-time exercise. New content is published constantly — blog posts, product updates, campaign landing pages, social ads. Manual reassessment every time is impractical.
GreenClaims Scanner runs this assessment automatically on your live website every 24 hours, flags new violations as content is published, and provides a risk score per page aligned with the ECGT framework. Start free — no credit card required for the initial scan.
For teams managing multiple brands or client websites, the API integration allows claims to be checked before they are published.