Greenwashing is when a company makes a product or practice sound more environmentally friendly than it really is. In fashion it appears as vague labels, selective facts and green-looking design that runs ahead of the evidence.
This guide belongs to the wider topic of ethical business in fashion. It explains how regulators describe misleading claims and what a shopper or a small label can check before believing, or making, one. It is general information, not legal or compliance advice.
Why misleading claims are common in clothing
Clothing is bought on image as much as on function, and many of its environmental effects happen out of sight, in fibre production, dyeing and distant factories. That gap between what a buyer sees and what happened upstream is where loose wording thrives. A hang tag can say a great deal in a few words, and a shopper in a shop or on a phone has little time to test it.
The UK Competition and Markets Authority publishes a Green Claims Code that sets out how consumer law applies to environmental claims. It states that claims must not mislead consumers by giving them an inaccurate impression, even if those claims are factually correct. That is a useful starting point: a claim can be accurate word for word and still deceive through what it leaves out or how it is presented.
Vague and absolute wording
The most recognisable form is a broad term with no explanation. The CMA guidance notes that terms like green, sustainable or eco-friendly, especially if used without explanation, are likely to be seen as suggesting that a product or business as a whole has a positive environmental impact, or at least no adverse impact. Its position is that unless a business can prove that, it risks falling short of its legal obligations, as set out on the CMA’s guidance page.
The EU has taken a similar line. The recitals of the EU directive on empowering consumers for the green transition say that generic environmental claims should be prohibited when recognised excellent environmental performance cannot be demonstrated. The examples it lists include environmentally friendly, eco-friendly, green, climate friendly, biodegradable and biobased. When the specification of the claim is given in clear and prominent terms on the same medium, such as the packaging or the online selling page, it is not treated as a generic claim.
For a reader, the lesson is practical. A phrase such as “conscious collection” tells you nothing until it is tied to something measurable: which material, which process, compared with what.
Selective claims and hidden trade-offs
A second pattern is a true statement about one small part of the story. The CMA gives a garment example: a garment could accurately be described as organic but a huge amount of water is used in its production. Another warning in the same guidance is that businesses should not focus claims on a minor part of what they do if their main or core business produces significant negative effects, as described in the Green Claims Code.
Terms with a widely assumed meaning need particular care. The guidance uses jeans as a worked case: claiming a pair of jeans are organic when only 35% of their material is from organic cotton is almost certainly misleading, according to the CMA’s own example. A more precise statement of the actual share, with the other materials listed, is less likely to mislead.
Offsetting, future goals and ordinary legal requirements
Some claims lean on the future or on money spent elsewhere. The CMA states that claims about future goals should only be used for marketing purposes if the business has a clear and verifiable strategy to deliver them, and that claims about environmental ambitions must be in proportion to actual efforts, per its published principles.
On offsetting, the EU directive text adds to the list of banned practices claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions. The same text says the ban should not prevent companies from advertising their investments in environmental initiatives, as long as the information is not misleading.
A further trick is to present the ordinary as special. The CMA says claims must not suggest that products provide environmental benefits which are, in fact, necessary standard features, and the EU list of banned practices includes presenting requirements imposed by law on all products within the relevant product category as a distinctive feature of the trader’s offer. Both statements appear in the CMA guidance and the EU directive respectively.
Labels, logos and imagery
Green leaves, earth tones and badge-style graphics can imply certification where none exists. The CMA notes that the visual presentation of a claim, meaning the images, logos, packaging and colours used, is an important part of the overall presentation. It adds that there should be a direct and verifiable link between a symbol and the meaning consumers are likely to draw from it, in the Green Claims Code.
The EU directive goes further on labels. Its recitals say the displaying of sustainability labels which are not based on a certification scheme, or which have not been established by public authorities, should be prohibited, as the directive’s preamble explains. For shoppers this means a badge deserves one question: who runs the scheme behind it, and where are its criteria published?
How the rules are changing in Europe
The directive on empowering consumers is the EU’s main response to misleading green claims. Member states had to adopt and publish the measures needed to comply with it, and the text states that they shall apply those measures from 27 September 2026, as published on EUR-Lex. That date has now passed, so the bans apply through each member state’s own law. National laws, enforcement bodies and penalties therefore differ by country, and anyone selling in a specific market should check that country’s own rules.
Claims about a company as a whole also connect with what it publishes about itself, which is a separate subject covered in corporate sustainability reporting. Environmental wording is only part of ethical marketing; claims about pay and safety in factories raise their own questions, which are explained under garment worker rights.
Practical checks before believing a claim
A short routine helps whether you are buying or writing the copy for a small label.
- Look for specifics. A named material, a stated share and a clear scope are more informative than an adjective.
- Check what the claim covers. The CMA expects claims about one aspect to make clear what is being claimed and what it relates to.
- Ask for the evidence. The same guidance says businesses should hold robust, credible, relevant and up to date evidence that supports their claims, as stated on the CMA’s page.
- Look for conditions. If a claim is only true under certain circumstances, those caveats should be clear and close to the claim.
- Compare like with like. Comparisons should be based on clear, up to date and objective information, according to the same guidance.
- Trace a label to its scheme. A logo should lead to a published standard, not only to a brand’s own page.
Small businesses can turn the same list around: write the plainest accurate claim, keep the supporting records, and drop any adjective that cannot be defended.
Frequently asked questions
Is a vague word like eco-friendly always illegal?
Not necessarily everywhere, and the position depends on the country and the context. The CMA guidance says such terms are likely to be seen as suggesting a positive overall impact, and the EU directive prohibits generic claims where recognised excellent environmental performance cannot be demonstrated, through national measures that now apply. Local law and legal advice settle individual cases.
Can a true claim still be greenwashing?
Yes. The CMA guidance states that claims can mislead even when they are factually correct, if the overall impression is deceptive.
Does buying offsets make a product neutral?
Under the EU directive, a claim of a neutral, reduced or positive greenhouse gas impact based on offsetting is among the banned practices, which now apply through each member state’s national measures.
Where can the official texts be read?
The CMA guidance is on gov.uk and the EU directive is on EUR-Lex, both linked above.
