Public Relations & Reputation Management

ESG Communications: Avoiding Greenwash

Environmental claims face tougher scrutiny—and silence brings its own risk. Communicate clearly with data, scope and evidence to avoid greenwash.

What changed in June 2025 regarding the EU’s Green Claims Directive?

It became law across the EU overnight.

Negotiations were paused, so brands must follow existing national rules for now.

It eliminated the need to substantiate environmental claims.

It legalized using generic terms like “eco‑friendly” without proof.

With EU talks paused, companies should default to national regimes and keep robust evidence for any environmental claims.

From April 2025 in the UK, what new enforcement risk applies to misleading green claims?

Fines are capped at £10,000 for all firms.

The CMA can impose fines up to 10% of global turnover (or £300k) under the DMCC Act.

Only a gentle warning letter is possible.

Only the ASA can act; the CMA has no role.

Under the DMCC Act’s consumer enforcement, the CMA gained direct fining powers for breaches including misleading environmental claims.

Which claim type is most likely to draw scrutiny in 2025?

Clear, specific claims tied to verified data.

Vague, absolute terms like “100% green” with no context or evidence.

Plain descriptions of a single, limited benefit with proof.

Statements explicitly acknowledging trade‑offs with sources.

Regulators caution against generic or absolute environmental claims unless they can be fully substantiated and not misleading by omission.

What’s a safer approach to talking about carbon offsets in marketing?

Explain methods, limits and data—avoid implying neutrality without robust proof.

Use “carbon neutral” because offsets were purchased once.

Treat offsets as a substitute for reducing emissions.

State neutrality for the whole business based on a single product’s offsets.

UK rulings and guidance highlight the risk of over‑claiming neutrality; marketers should be specific and transparent about what offsets do and don’t cover.

What is “greenhushing” in 2025 ESG communications?

Publishing third‑party‑verified impact data.

Deliberately downplaying or withholding progress to avoid scrutiny.

Exaggerating progress to win praise.

Lobbying for stricter climate policy.

Advisories in 2025 define greenhushing as the opposite risk to greenwashing—silence that undermines transparency and trust.

If a green claim is challenged, what’s the first best‑practice step?

Blame the publisher and provide no documentation.

Delete the claim and stay silent to avoid attention.

Repost the same message across channels for consistency.

Review the underlying evidence and issue a clear correction if needed.

Regulators expect claims to be truthful and evidence‑based; prompt, transparent corrections reduce legal and reputational risk.

Which detail helps keep environmental messages compliant and comprehensible?

Scope and timeframe—for example, what part of the lifecycle and which years the claim covers.

Excluding any mention of product trade‑offs.

Only aspirational targets without interim data.

Use of broad slogans with no boundaries.

Specific scope and dates reduce the risk of misleading by omission and align to 2025 expectations for clarity.

Post‑pause in the EU, how should multinationals approach pan‑EU sustainability messaging?

Meet the strictest national standard you operate under and maintain audit‑ready evidence.

Adopt the loosest country standard to maximize claims.

Stop substantiating until the EU finalizes rules.

Rely on supplier assurances without any checks.

With EU‑wide rules delayed, aligning to the most stringent applicable standard and strong documentation is a prudent risk‑management approach.

Which message style is both audience‑friendly and regulator‑friendly?

Sweeping statements covering the entire lifecycle without proof.

Plain language with concrete metrics and sources.

Emotional appeals with no data.

Technical jargon and unreferenced claims.

Guidance consistently favors clarity and specificity over vague or technical language that can mislead.

Why is publishing thoughtful ESG progress (vs. greenhushing) encouraged in 2025?

Because competitors will otherwise copy your claims.

Because aspirational slogans are sufficient proof.

It builds trust when backed by data, while silence can raise suspicion.

Because regulators say silence is illegal.

Advisories and trends highlight that transparency with evidence supports credibility; silence may undermine confidence among stakeholders.

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