A German shampoo label reads: "97% ingredients of natural origin." The ingredient list could not substantiate the claim. Better still: the Hungarian label of the same product also carried a "carbon neutral" claim — one that did not appear on the German original. If that is ever challenged, the manufacturer will most likely be unable to prove it.
These are not textbook examples: Zsolt Takács, owner-CEO of ESGinfo.hu and ReadyPass, encountered them in his audit work — from toilet paper through cosmetics to fruit drinks, claims like "80% eco-friendly packaging" or "made from 100% recycled material" appear regularly, with no evidence behind them.
Why has this become dangerous right now?
From 27 September 2026, the EmpCo Directive ((EU) 2024/825) treats unsubstantiated green claims as an unfair commercial practice — we covered the details in our greenwashing-stop article. From then on, the question is not whether the green lily looks good on the packaging, but whether you can back it up.
What's at stake? An analogy on fines
The sanction regime for green claims is still taking shape, but sustainability regulation already offers a benchmark: failing to file an ESG report can draw a fine of up to 1% of revenue, and up to 3% for accumulating infringements. Zsolt Takács's illustration: for a company with HUF 100 million (~€250k) in revenue, the 1% fine stings — the 3% one "certainly takes half the profit; at a serious company, the managing director will be held accountable for a fine like that."
Deliberate fraud or ignorance?
Audit experience shows greenwashing splits into three layers — and the ranking may surprise you:
1. Ignorance and carelessness (the most common). Non-specialists — marketing or packaging design — add good-looking green labels without knowing that a burden of proof comes with them. 2. Aware, but not malicious. "Some know the product isn't quite that — but they also know the customer buys it if it's printed on the box." 3. Deliberate deception (the rarest). Someone knows the product harms the environment and still puts a green claim on it.
The paradox: the bad-faith actor is quickly exposed and can be dealt with — ignorance can only be dismantled through long education. Training alone is not enough: teams need to prove in practice that they can tell a third-party-certified logo from a "freely drawn" green label. (And greenwashing is only one variety: there is bluewashing — water-related claims — and pinkwashing too.)
Supplier declarations are not gospel either
The green claim often does not originate with the brand but arrives from the supply chain — as a declaration. Audits regularly turn up incomplete or questionable product declarations; an engagement is running right now in which the truthfulness of an Asian supplier's declaration has to be verified by an external expert. If your "recycled content" claim rests on your supplier's paperwork, you are carrying your supplier's risk as well.
How to make green claims provable
1. Claim inventory: collect every environmental claim — packaging, webshop, advertising, and every language variant separately (remember the Hungarian-label case). 2. Evidence pairing: a trusted data source for each claim — measurement, certificate, documented calculation. 3. Validate supplier declarations: third-party verification for critical claims. 4. Structured, trusted storage: keep the supporting data signed and verifiable — this is exactly what the digital product passport is for. 5. Clean-up: whatever cannot be proven comes off the product. That is cheaper than the fine.
Frequently asked questions
Is the local distributor liable for a claim on the localised label?
Every actor in the labelling chain carries responsibility — if the localised label gains a claim absent from the original, the local company can be held to account for it.
Is a "carbon neutral" certificate based on offsetting enough?
EmpCo specifically restricts climate-neutrality claims based solely on offsetting. The safe route is presenting the actual emission data.
What counts as "evidence"?
Verifiable data tied to the specific product: test reports, third-party certification, documented calculations — stored in a trusted way and made accessible.
Green claims only with evidence. ReadyPass makes the data behind environmental claims available in a structured, eIDAS-signed, verifiable form — so your marketing survives the audit and the regulator.
