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12 Worst Greenwashing Examples (2025-2026 Update): Fines & Rulings — GreenClaims Scanner

12 Worst Greenwashing Examples (2025-2026 Update): Fines & Rulings — GreenClaims Scanner
Quick answer: Notable cases: TotalEnergies, found by the Paris Judicial Court (October 2025) to have misled consumers about "carbon neutrality"; DWS, fined $25M by the SEC (2023) and €25M by German prosecutors (2025); KLM, ruled to have made 15 misleading "Fly Responsibly" claims (Amsterdam court, March 2024); and Shein, fined €40M in France and €1M in Italy (2025) for unproven eco-claims.
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When the Paris Judicial Court ruled in October 2025 that TotalEnergies had misled consumers about its "carbon neutrality" ambitions, it marked the first time a European court held a major oil and gas company accountable in this way for how it markets its climate strategy. It will not be the last. Regulators and courts across the EU, UK and Canada have spent the past six years picking apart vague, unverifiable environmental claims from household brands — sometimes with fines, sometimes with binding commitments, always with the same lesson for the company on the receiving end.

The rules have also caught up with the marketing. The EU green claims rules (Directive 2024/825), formally the "Empowering Consumers for the Green Transition" Directive amending the Unfair Commercial Practices Directive, has applied since 27 September 2026. It bans vague claims like "eco-friendly" unless backed by recognised excellent environmental performance, sustainability labels not tied to a certification scheme or public authority, and claims that a product is climate-neutral based on carbon offsetting alone. The twelve cases below, drawn from official regulator and court decisions, show what national authorities were already penalising before that EU-wide law existed — and the kind of claim they are now positioned to target even harder.

CompanyClaimWho actedOutcomeYear
Shell"Powering Progress" ads overstated the low-carbon share of its businessUK ASAThree ads banned2023
TotalEnergies"Carbon neutrality by 2050" claims on its French siteParis Judicial Court3 statements ruled misleading, ordered removed2025
Eni"Eni Diesel+" implied the whole fuel was low-emissionItalian AGCM€5M fine, later annulled on appeal2020 / 2024
KLM"Fly Responsibly" and CO2ZERO offsetting claimsAmsterdam District Court15 of 19 statements ruled misleading and unlawful2024
Ryanair"Europe's lowest emissions airline"UK ASAAds banned, claim unsubstantiated2020
H&M"Conscious" collection and sustainability messagingDutch ACMCommitted to clearer info, €500,000 donation, no fine2022
SheinVague eco-claims plus inflated discount claimsFrench DGCCRF; Italian AGCM€40M fine (France); €1M fine (Italy)2025
DWS"ESG leader" positioning not matched by its investment processSEC (US); Frankfurt prosecutors$25M fine (2023); €25M fine (2025)2023 / 2025
HSBCNet-zero financing and tree-planting postersUK ASATwo ads banned for omitting fossil-fuel financing2022
Microsoft"Carbon negative by 2030" pledge vs its actual footprintSelf-reported (Environmental Sustainability Report)Emissions up 23.4% vs 2020 baseline2025
Coca-Cola"100% recycled plastic" bottle claimsBEUC / ClientEarth / ECOS complaintLabelling revised after EU pressure2023 / 2024
Keurig"Widely recyclable" K-Cup podsCompetition Bureau CanadaC$3M penalty plus C$800,000 donation2022

Energy and fossil fuels

1. Shell — two rulings on "carbon neutral" driving and clean energy

Shell has been caught twice. In September 2021, the Dutch Advertising Code Committee ruled that Shell's "Drive CO2 neutral" campaign — which told drivers that paying one extra cent per litre funded offsetting projects that made their driving carbon-neutral — was misleading, because Shell could not demonstrate the claim with the certainty it implied. The committee's finding is not legally binding, but it recommended Shell drop the claim.

Then, in June 2023, the UK Advertising Standards Authority banned three "Powering Progress" ads that highlighted renewable electricity and wind projects, ruling they created a misleading impression of Shell's overall business, which at the time relied on fossil fuels for the vast majority of its revenue. Shell was told future ads must not exaggerate the share of low-carbon energy in its business. Lesson: a true statistic about one product line can still mislead if it implies something about the whole company.

2. TotalEnergies — "carbon neutrality by 2050" found misleading in court

In October 2025, the Paris Judicial Court partially upheld a case brought by Greenpeace France, Les Amis de la Terre and Notre Affaire à Tous, supported by ClientEarth. Of 44 communications examined, the court found three statements on TotalEnergies' French consumer website — about its "ambition" to reach carbon neutrality by 2050 and being "a major actor in the energy transition" — constituted misleading commercial practices. The court ordered the statements removed, the ruling published on the homepage for 180 days, and damages paid to each claimant association. Most of the NGOs' other claims were dismissed. See also our guide to carbon-neutral claim rules for what "ambition" language can and cannot say under the new EU regime.

3. Eni — "Eni Diesel+" blurred a biofuel blend with the whole product

Italy's competition authority, AGCM, fined Eni €5 million in January 2020 — its first greenwashing case — for a diesel campaign that attributed positive environmental claims to the entire fuel, when only a roughly 15% biofuel component (branded "Green Diesel," made partly from palm oil) justified any environmental framing. Eni appealed, and in April 2024 Italy's Council of State overturned the fine, ruling no unfair commercial practice had occurred. The case remains a cautionary tale either way: blending one green ingredient into a product name invites scrutiny of the whole claim, and outcomes on appeal can take years to settle.

Aviation

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4. KLM — first airline found guilty of greenwashing in the EU

On 20 March 2024, the Amsterdam District Court ruled that 15 of 19 environmental statements challenged by Fossielvrij NL were misleading and unlawful, covering the "Fly Responsibly" campaign, the CO2ZERO offsetting add-on, and KLM's "Real Deal Days" marketing. The court found KLM painted "too rosy a picture" of measures that only marginally reduced its environmental impact, and that calling sustainable aviation fuel simply "sustainable" was too absolute a claim. KLM was ordered to pay the NGO's legal costs — the first such judgment against an airline in Europe.

5. Ryanair — "lowest emissions" claim banned for weak evidence

In February 2020, the UK ASA banned Ryanair ads claiming it was "Europe's lowest emissions airline," after finding the airline's supporting data — a 2011 efficiency ranking that excluded several competitors — could not substantiate the comparison it was making in 2019. The ads were told not to run again in that form. The case is a reminder that a comparative claim needs current, complete data, not a decade-old chart.

Fashion

6. H&M — "Conscious" claims lead to a Dutch regulator settlement

In September 2022, the Dutch Authority for Consumers and Markets (ACM) found that H&M and Decathlon used general terms such as "Conscious" and "Ecodesign" without explaining what they meant, and that H&M talked about its future intentions without disclosing its current sustainability performance — creating too flattering a picture. Both retailers committed to clearer information going forward; H&M donated €500,000 and Decathlon €400,000 to sustainability causes, and the ACM imposed no formal fine. For the wider pattern in apparel, see our piece on fast-fashion greenwashing.

7. Shein — fined in both France and Italy in the same year

France's DGCCRF fined Shein's operating entity €40 million in July 2025, following a near year-long probe into fake discounts and unsubstantiated environmental claims — the company could not back up its stated efforts to cut emissions. A month later, in August 2025, Italy's AGCM fined Shein €1 million for vague, generic and sometimes misleading environmental messaging across its site (including claims tied to hashtags like #SHEINTHEKNOW), and found its pledge to cut emissions 25% by 2030 was undercut by actual emissions increases in 2023 and 2024. Two regulators, two separate fines, the same underlying problem: broad sustainability language with no comparable substantiation behind it.

Finance

8. DWS — fined on two continents for its "ESG leader" positioning

DWS, the asset manager majority-owned by Deutsche Bank, agreed to pay the SEC $25 million in September 2023 — $19 million for materially misleading statements about how thoroughly it applied ESG criteria in actively managed funds, and $6 million for separate anti-money-laundering failures. Its then-CEO, Asoka Wöhrmann, had already resigned in June 2022, days after police raided DWS's Frankfurt offices as part of the same investigation. In April 2025, Frankfurt prosecutors closed their own three-year probe with a further €25 million fine for negligent misstatements in ESG marketing and documentation. Combined, the two fines total roughly $52 million — among the largest greenwashing penalties on record for an asset manager. See our overview of ESG reporting and greenwashing risk.

9. HSBC — banned for omitting its fossil-fuel financing

In October 2022, the UK ASA banned two HSBC bus-stop posters — one citing its up-to-$1-trillion net-zero financing pledge, the other its tree-planting programme — because they omitted HSBC's continued, substantial financing of fossil fuel projects. It was the first ASA ruling against a bank on greenwashing grounds, and it set the template regulators still use: a genuinely true commitment can still mislead if it hides a much larger, contradicting fact.

Tech

10. Microsoft — emissions rising despite a 2030 carbon-negative pledge

Microsoft has not been fined, but its own numbers tell a cautionary story. Its 2025 Environmental Sustainability Report (covering FY2024) shows total emissions up 23.4% against its 2020 baseline, driven mainly by data-centre construction for AI and cloud growth — even as Scope 1 and 2 emissions fell nearly 30% and Scope 3 emissions rose around 26% over the same period. Microsoft has been transparent about the gap between its 2030 "carbon negative" ambition and its current trajectory, which is precisely why it hasn't drawn regulatory action — but it illustrates why ambition-only claims, even honestly disclosed ones, need constant updating against reality.

Food and packaging

11. Coca-Cola — "100% recycled" bottle claims revised under EU pressure

In November 2023, the European consumer group BEUC, with support from ClientEarth and ECOS, filed a complaint against Coca-Cola, Danone and Nestlé over "100% recycled" and "100% recyclable" bottle claims, arguing that components like caps, labels and adhesives are typically not recycled content at all. Coca-Cola subsequently revised its labelling to clarify that the "100% recycled" claim applies only to specific parts of the bottle, not the whole product. For the broader pattern in food and drink marketing, see green claims in food and organic labelling.

12. Keurig — recyclability claims that didn't hold outside two provinces

In January 2022, Canada's Competition Bureau found Keurig Canada's claims that its K-Cup pods were recyclable were false or misleading in most of the country, since municipal recycling programmes outside British Columbia and Quebec did not accept them. Keurig agreed to pay a C$3 million penalty, donate C$800,000 to an environmental charity, cover C$85,000 of the Bureau's investigation costs, and correct its packaging. It's a textbook case for anyone making a blanket recyclability claim — recycling infrastructure varies by region, and "recyclable" needs a location qualifier. See our sustainable packaging claims guide for how to phrase this correctly.

The Six Sins of Greenwashing

In 2007, environmental marketing firm TerraChoice published "The Six Sins of Greenwashing," a framework that still maps neatly onto the cases above.

  • Hidden trade-off — highlighting one green attribute (recycled content) while ignoring a bigger impact elsewhere (manufacturing emissions).
  • No proof — a claim with no accessible evidence or certification behind it, the core problem in the DWS and H&M cases.
  • Vagueness — words like "eco-friendly" or "conscious" that are too broad to verify, as the Dutch ACM flagged in H&M's case.
  • Worshiping false labels — a label or badge that implies third-party certification when none exists.
  • Irrelevance — a true claim that's legally irrelevant, such as advertising a product as free of a substance already banned.
  • Lesser of two evils — a claim that distracts from the fact the product category itself carries a large footprint, echoed in the Shell and Ryanair rulings.

Directive 2024/825 effectively writes several of these sins directly into EU law: it targets vague, unsubstantiated claims and unverified sustainability labels by name. Our banned green terms list tracks which specific words now carry the most legal risk.

Why companies keep doing it

None of the companies above set out to break the law. Sustainability claims sell, and until recently the legal cost of an unsubstantiated claim was low — an advertising ban, a reputational headline, sometimes a modest fine measured against a marketing budget. The cases here — from an outdated comparison chart at Ryanair to a "Conscious" label with no defined meaning at H&M — mostly involve claims that were technically defensible in isolation but misleading in the full context a regulator eventually supplied.

What has changed is the cost side of that calculation. Coordinated EU enforcement, court rulings that order a statement removed from a homepage for six months, and asset managers being investigated on two continents for the same underlying claim all raise the price of getting it wrong.

What these cases mean for your business

Every case above shares a pattern: a claim that was broadly true in a narrow sense but created a misleading overall impression once a regulator looked at the full picture. That's exactly what Directive 2024/825 targets, and it's a far lower bar to trip than most compliance teams assume — you don't need to invent a fake certification to get caught, you just need to let a marketing claim outrun your evidence.

Before your next campaign goes out, check any claim that generalises from one data point, any label or badge you haven't licensed from a real certification body, and any "neutral" or "net zero" claim that relies partly on offsets. Our green marketing compliance checklist walks through this claim-by-claim. If you want a faster first pass, you can scan your website for the same categories of risky language regulators have already penalised above — it takes under a minute and flags exactly which claims need evidence behind them.

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