Introduction

Greenwashing refers to the practice of conveying a false or misleading impression to consumers about the environmental benefits of a product, service, or company (1). Ensuring the reliability of claims—meaning they are trustworthy, relevant, and accurate—serves as a safeguard against greenwashing (1). Green claims are a specific type of sustainability claim that focuses on the environmental attributes of a product, service, process, or organisation (1). Governments play a critical role in preventing greenwashing by establishing regulatory frameworks that set clear requirements, addressing a regulatory gap that enables the proliferation of misleading or unsubstantiated claims (2). This report examines 23 regulatory instruments across 12 jurisdictions to assess emerging trends, identify progress, and highlight limitations in the evolving regulatory landscape (3-4).

A mapping of policy responses to greenwashing

Policy responses rely on various legal instruments, including consumer protection and competition laws, dedicated guidelines, advertising self-regulation, sector-specific legislation, and specific greenwashing laws (4). These regulatory responses can be broadly classified into three categories: prohibitions or bans, disclosure requirements, and non-binding guidance (7). Most countries take a cross-sectoral approach, although some have adopted sector-specific regulations focusing on high-impact sectors like textiles, electronics, and food (9). Frameworks vary in stringency from binding laws establishing enforceable legal obligations to non-binding guidance offering interpretive tools, with many countries combining both approaches (11-12). Very few countries include formal definitions of greenwashing within binding legal instruments (14). Regulations share core principles requiring claims to demonstrate truthfulness, substantiation, clarity, and transparency (16-17). Enforcement is largely entrusted to existing consumer protection or competition authorities, relying on sanctions such as administrative fines and corrective measures alongside compliance monitoring mechanisms (20). Implementation depends on stakeholder engagement, the integration of voluntary sustainability standards (VSSs), and access to credible, verifiable data (22-23).

Analysis and discussion of findings

While most countries converge on core principles, the pathways to credible evidence are not always specified, creating legal uncertainty and risks of inconsistent enforcement (29-30). Collecting credible, verifiable, and comparable data remains a major barrier, and applying a one-size-fits-all substantiation approach risks creating disproportionate impacts on smallholders and small and medium-sized enterprises (SMEs) (30). VSSs provide traceability systems, monitoring protocols, and audit procedures that directly support substantiation and transparency requirements (30). In a review of Indian businesses, respondents acknowledged that VSSs are useful reference points for businesses seeking to improve transparency and compliance, acting as complementary mechanisms rather than substitutes for regulation (31-32).

Conclusion and recommendations

To strengthen legal design, policy-makers should strengthen the design of substantiation requirements by providing clearer guidance on acceptable evidence and methodologies (33). Regulators must adopt proportionate approaches that reflect differences in company size, sector, and position in the value chain to ensure regulation improves credibility without excluding smaller actors (33). To improve implementation, governments should invest in data infrastructure and producer support through technical assistance and shared data platforms (33). Furthermore, regulators should combine enforcement with guidance and awareness raising, and promote cooperation and experience sharing across jurisdictions (34). Finally, authorities should clarify the role of VSSs by setting clear recognition criteria regarding governance, independence, audit quality, and data transparency, rather than endorsing specific schemes (34).