How to Talk About Your ESG Progress Without Greenwashing

You've started tracking your emissions. You've invested in LED lighting, reduced waste, written policies. Now you want to tell customers about it — on your website, in proposals, on product packaging.

Be careful. The way you describe your progress matters more than you think. Regulators across Europe, the UK, and the US are actively cracking down on vague or misleading environmental claims. And the rules apply to suppliers of all sizes, not just consumer brands.

This guide covers what you can say, what you can't, and how to market your ESG efforts honestly.

Why This Matters Now

Three regulatory shifts are changing what suppliers can claim:

EU Empowering Consumers Directive (2024/825)

This is already law. Member states must apply it from September 2026. Key changes:

• Generic claims banned. You cannot say "eco-friendly," "green," "environmentally friendly," or "natural" without demonstrating recognized excellent environmental performance relevant to the claim.
• "Carbon neutral" via offsets banned. You cannot claim a product or company has a neutral, reduced, or positive environmental impact based solely on carbon offsetting schemes.
• Sustainability labels must be certified. You cannot create your own "green" badge or use a label that isn't based on an official certification scheme.

Penalties follow the Unfair Commercial Practices Directive: fines up to 4% of annual turnover.

EU Green Claims Directive (proposed)

Still in legislative process, but expected to require:

• Scientific substantiation (life-cycle based) for any environmental claim
• Independent verification before the claim can be used in marketing
• A ban on vague claims unless backed by recognized eco-labels

When adopted, member states will have 24 months to transpose it. Practical enforcement likely from 2027-2028, but the direction is clear: substantiate or don't claim.

UK Green Claims Code

The UK Competition and Markets Authority (CMA) has been actively enforcing its Green Claims Code since 2021. Six principles: claims must be truthful, clear, not omit important information, compare fairly, be substantiated, and consider the full product life cycle. The CMA has investigated and taken action against companies — including in fashion and FMCG — for misleading "sustainability" collections.

FTC Green Guides (US)

The US Federal Trade Commission's Green Guides require environmental claims to be truthful, substantiated, and not misleading. Updated guides addressing carbon offsets, "recyclable" claims, and "net zero" language have been under review. Violations can result in fines exceeding $50,000 per violation.

The Five Claims That Get Suppliers in Trouble

1. "We are a sustainable supplier"

Why it's risky: "Sustainable" is undefined. Sustainable compared to what? By which measure? This is exactly the type of generic claim regulators are targeting.

Say instead: "We reduced our energy consumption by 12% in 2024 through equipment upgrades and operational changes." Specific. Measurable. Verifiable.

2. "Carbon neutral" or "Climate neutral"

Why it's risky: Under the EU Empowering Consumers Directive, you cannot claim carbon neutrality based on purchasing offsets. Even outside the EU, "carbon neutral" claims invite scrutiny because they imply zero impact — which is almost never true for a manufacturing or logistics supplier.

Say instead: "Our Scope 1 and 2 emissions were 245 tonnes CO2e in 2024, down 18% from 2023. We are working to reduce further through energy efficiency and renewable electricity procurement." Report the numbers. Show the trend. Skip the label.

3. "Eco-friendly packaging" or "Green materials"

Why it's risky: "Eco-friendly" is one of the most commonly flagged terms. Friendly compared to what? The full life cycle? Just one stage? And "green" is meaningless without context.

Say instead: "Our packaging contains 70% post-consumer recycled content" or "Our packaging is recyclable in standard municipal recycling streams in the EU." Specific, verifiable, and defensible.

4. "We are committed to sustainability"

Why it's risky: It's not technically a claim, which is why companies love it. But regulators and customers increasingly see it as empty if there's no data behind it. It doesn't differentiate you — every company says this.

Say instead: "We track our energy, water, and waste data annually. Our environmental policy covers emissions reduction, waste diversion, and supplier assessment. Here's our latest data." The commitment is implied by the action.

5. "Net zero by 2030"

Why it's risky: Net zero targets require science-based pathways, interim milestones, and clear scope definitions. Setting a target without a credible plan to achieve it is a claim regulators can challenge. If your target relies heavily on offsets rather than actual reductions, it's particularly vulnerable.

Say instead: "We have set a target to reduce Scope 1 and 2 emissions by 42% by 2030, against a 2023 baseline. Our reduction plan includes switching to renewable electricity, fleet electrification, and process efficiency improvements." State the target, the scope, the baseline, and the plan.

The Rule: Data Beats Labels

Every safe environmental claim follows the same pattern:

Specific metric + time period + methodology (if asked)

Instead of labels like "green," "clean," "sustainable," or "carbon neutral," report:

• What you measured
• What the number was
• How it changed
• What you're doing next

This is exactly what ESG questionnaires ask for — and it's exactly what makes marketing claims defensible. The data you gather for EcoVadis, CDP, or your customer's custom questionnaire is the same data that makes your marketing bulletproof.

What About B2B vs. B2C?

You might think these rules only apply to consumer-facing brands. They don't.

• The EU Empowering Consumers Directive primarily targets B2C claims, but B2B claims can still fall under unfair commercial practices if they're misleading.
• The proposed Green Claims Directive is expected to cover B2B environmental claims as well.
• Your customers' procurement teams are increasingly trained to spot greenwashing in supplier proposals. Vague claims don't win contracts — data does.

Even if regulators aren't watching your B2B pitch deck, your customers are.

A Practical Framework for Supplier Marketing

Before making any environmental claim on your website, proposals, or packaging, run it through these three questions:

1. Can I put a number on it?

If yes, use the number instead of the adjective. "Reduced waste by 35%" beats "low-waste manufacturing."

If no, don't make the claim.

2. Can I show the evidence if challenged?

Utility bills, waste transfer records, certification documents, calculation methodologies. If you can't produce evidence within a reasonable timeframe, the claim is unsubstantiated.

3. Does the claim cover the full picture?

Claiming your product is "made with renewable energy" while your shipping and logistics are carbon-intensive is misleading by omission. If you make a claim about one part of your operations, be transparent about what it does and doesn't cover.

What You Can Safely Claim

Not everything is off-limits. Data-backed statements and certified credentials are solid ground:

Notice the pattern: third-party verification, specific numbers, defined scope, and clear timeframes.

What If You're Early in Your ESG Journey?

Most suppliers reading this don't have EcoVadis Gold or zero-waste facilities. That's fine. Honest progress is more credible than premature claims.

Instead of making claims you can't back up, try:

• "We started tracking our carbon emissions in 2024." Shows initiative without overclaiming.
• "We are building our ESG data infrastructure to respond to customer assessments." Honest about where you are.
• "Our first sustainability data report covers Scope 1 and 2 emissions, workforce metrics, and core policies." Specific about what you have.

Customers and regulators don't expect perfection from SMEs. They expect honesty and a credible direction of travel.

Conclusion

The safest marketing strategy for your ESG progress is also the most effective one: let the data speak. Specific numbers, verifiable credentials, and honest acknowledgment of where you're still improving will always outperform generic labels that regulators are actively banning.

If you're tracking your data properly, you already have everything you need for credible marketing. Use the numbers from your assessments and reports — they're your best sales tool and your best legal protection.