Greenwashing, question by question

Greenwashing means presenting a product, a service or a company as better for the environment than it actually is. In advertising it rarely takes the form of an outright lie. It takes the form of a vague claim, a green visual, a self made label or a feature promoted as an advantage when the law already requires it of everyone. Such a communication could be qualified as greenwashing once it leaves the public with an environmental impression the facts do not fully support.

An ad for sustainable bananas, with nothing explaining what sustainable covers, would be a generic environmental claim. A round green badge reading 100% natural ingredients could suggest an official certification that does not exist. A bottle stating compliant with European regulation turns a legal obligation into a selling point. A product described as carbon neutral raises the same concern. All of these come from real cases we have assessed.

Ask four questions. Is the wording concrete or merely suggestive, like sustainable or responsible on their own. Does the visual imitate a label while no independent body certifies anything. Is the feature promoted a genuine advantage or a legal requirement that already applies to every product. Does the message claim carbon neutrality at product level. If a single answer is uncomfortable, the communication could carry a greenwashing risk.

A claim is generic when it suggests environmental performance without saying what it covers, and no clear, prominent specification appears on the same medium. Sustainable bananas stays generic. Sustainable biofuel followed by 60% less CO2 than the average becomes specific, because the figure directly qualifies the claim. The specification has to sit on the communication itself, not on a page someone might visit later.

Yes, provided its origin is clearly identified, certified by a third party, and its scope is not overstated. The EU Ecolabel, FSC, MSC or Fairtrade are widely recognised. A self awarded label created by the brand itself, or simply a green circle with a leaf, could mislead the public into assuming an official certification exists. In that case an explanation or a redirect link on the communication is essential.

Not at the level of a product, a service or a company. Carbon neutral, zero carbon, climate neutral and net zero are treated as equivalent terms. Claiming, on the basis of offsetting, that a product has a neutral impact is not allowed. Saying we are working towards a carbon neutral society remains possible, because the scale is collective. Announcing that the company will be carbon neutral by 2050 would raise the same problem.

The JEP is Belgium's advertising self regulatory body, known in French as the Jury d'Ethique Publicitaire. It handles complaints from the public about advertising said to be misleading or contrary to the profession's ethical rules, environmental claims included. It can ask for a communication to be changed or withdrawn. It is not a court, yet its decisions carry weight in the sector and are published.

No. If an environmental requirement already applies to every product in the category on the European market, presenting it as a quality specific to your offer turns a general obligation into a commercial argument. A plastic bottle stating compliant with European packaging regulation is exactly that case. The wording can be implicit, you do not need to write exclusive or unique for the problem to arise.

Directive (EU) 2024/825, known as Empowering Consumers for the Green Transition, applies from 27 September 2026. It defines what a generic environmental claim is and frames carbon neutrality claims based on offsetting. In practice a vague claim will have to be specified in clear and prominent terms on the same medium, failing which it could be treated as misleading.

Three things. A complaint before the JEP, which can lead to a request to amend or withdraw the campaign, with a published decision. A reputational risk, often costlier than the campaign itself. And a legal risk under misleading commercial practices rules. We deliberately quote no article and no fine amount here, since those depend on the applicable framework and should be confirmed by your legal counsel.

Specify every claim on the medium itself, with a verifiable fact rather than an adjective. Drop sustainable or responsible when they stand alone. Use only labels certified by a third party and avoid any visual that merely looks like one. Do not claim carbon neutrality at product level. Do not sell a legal obligation as an advantage. Finally, keep the evidence behind every figure you publish.

Run the creative through a structured analysis before the media booking. Each question is settled separately, generic claim, label, carbon neutrality, legal requirement sold as an advantage, exaggeration, visual and audio elements. The output is not a final verdict but a documented risk level, with the reasoning attached. That is what our tool does, and what your team can do manually using the same grid.