11 Real-World Examples of Greenwashing

Key Takeaways:

• Since 6 April 2025 the Competition and Markets Authority (CMA) can decide for itself that a business has broken consumer law and fine it up to 10% of global turnover, and misleading environmental claims fall within that power.
• Several of the cases below rested on true statements. HSBC could evidence its tree planting and Shell could evidence its renewable electricity customers, yet both campaigns were ruled misleading because they left out material context about the rest of the business.
• Oatly's "73% less CO2e" claim failed at the Advertising Standards Authority (ASA) because its evidence compared one product with whole milk, while viewers would read it as a claim about every Oatly product against any cow's milk.
• Claims about ESG processes are tested as hard as product claims. The US Securities and Exchange Commission (SEC) fined a DWS subsidiary $19 million over how it described its ESG integration controls, and the FCA's anti-greenwashing rule has covered every UK-authorised firm since 31 May 2024.
• The EU's Empowering Consumers for the Green Transition Directive applies from 27 September 2026, restricting generic environmental claims and product neutrality claims that rely on offsetting. UK businesses selling into EU markets are exposed to it.

Greenwashing is an environmental claim that gives customers or investors a better picture than the evidence supports. The 11 cases here each ended in a formal outcome: an advertising ruling, a court judgment, a regulatory settlement or a set of binding undertakings. Campaign accusations that never reached a regulator are left out. For each case you'll find what was said, who examined it, what they decided and what it means for anyone who writes, approves or signs off a sustainability claim.

Intent rarely decided these cases. Several of the companies had genuine environmental programmes, measured and funded. What went wrong was the description: a missing boundary, an absolute word, a proportion left unsaid. Each traces back to a drafting or data gap, and the Oatly and Shell rulings show precisely which gap.

What Counts as Greenwashing in the UK?

No single UK statute defines greenwashing. Three regimes do the work between them, and which one applies depends on who is making the claim and where it appears.

The Green Claims Code gives six tests. A claim must be truthful and accurate, clear and unambiguous, must not omit or hide important information, must compare fairly, must consider the full life cycle of the product or service, and must be substantiated. Nearly every case below failed at least one of them.

The 11 Cases at a Glance

1. Volkswagen and the "Clean Diesel" Campaign

This is the outlier, and it's worth starting with because it shows what sits at the far end of the scale.

On 18 September 2015 the US Environmental Protection Agency (EPA) issued a notice of violation to Volkswagen AG, Audi AG and Volkswagen Group of America. It alleged that software in 2.0-litre diesel cars from model years 2009 to 2015 detected official emissions tests and switched full emissions controls on only during them. In normal driving, the EPA said, the cars emitted nitrogen oxides at up to 40 times the standard.

The marketing charge came from the Federal Trade Commission (FTC) in March 2016. Its complaint described a seven-year "Clean Diesel" campaign, including Super Bowl spots, that sold or leased more than 550,000 cars on claims that they were low-emission and environmentally friendly. Some promotional material said the cars cut nitrogen oxide emissions by 90%.

Settlements announced in June 2016 committed Volkswagen to spend up to $10.03 billion on buybacks and compensation for nearly 500,000 2.0-litre vehicles, plus $4.7 billion on pollution mitigation and green vehicle investment. In its final report to the court in July 2020, the FTC said more than $9.5 billion had been repaid to buyers.

Most greenwashing isn't fraud at source. But this case is why regulators now ask how a figure was measured as well as what it says.

2. HSBC's Pre-COP26 Bus Stop Posters

In October 2021 two HSBC posters appeared at bus stops in Bristol and London. One said the bank aimed to provide up to $1 trillion in financing and investment to help clients transition to net zero. The other said it was helping to plant 2 million trees in the UK that would lock in 1.25 million tonnes of carbon over their lifetime.

The ASA received 45 complaints, including one from the campaign group Adfree Cities. HSBC supplied evidence for both claims. It also set out its 2030 targets: a 34% cut in absolute oil and gas financed emissions and a 75% cut in financed emissions intensity for power and utilities.

None of that saved the ads.

In its ruling of 19 October 2022, the ASA found that HSBC was still significantly financing businesses with notable carbon dioxide and greenhouse gas emissions, that consumers would not know this, and that it was material information the posters should have included. The ads breached CAP Code rules 3.1, 3.3 and 11.1.

For a bank, the context the ASA had in mind is essentially financed emissions, which the GHG Protocol treats as Scope 3 Category 15 (investments). A claim about the green slice of a lending book invites the question of what the rest of the book emits.

3. Shell and "Cleaner Energy", Then a Different Result

Shell's June 2022 campaign ran on a Bristol poster carrying the line "BRISTOL is READY for Cleaner Energy", plus a TV ad and a YouTube video. The broadcast versions said 1.4 million UK households used 100% renewable electricity from Shell. Adfree Cities complained on two grounds.

The ASA split its decision on 7 June 2023. It did not uphold the supply point, because qualifying text explained that the electricity came through the National Grid and was matched by Renewable Energy Guarantees of Origin (REGOs). It did uphold the omission point. Oil and gas investment and extraction made up the vast majority of Shell's business in 2022, the ruling said, so an ad suggesting a significant share of the business was lower-carbon needed to say what that share actually was. Repsol and Petronas ads were ruled against in the same round of decisions.

Then came a useful contrast. A later Shell TV ad, seen in June 2024, carried on-screen text saying 68% of Shell's 2023 global investments included oil and gas, 23% included low-carbon energy solutions and 9% went to non-energy products. The ASA received 75 complaints, including from Adfree Cities and Carbon Tracker, and found no breach. [Editor: confirm ruling date against the ASA page.]

Same company, same kind of message, opposite result. The published proportion made the difference.

4. Oatly's 73% Figure

Two Oatly TV ads first shown on 16 January 2021 featured children questioning their fathers' dairy habits. Small on-screen text said Oatly generated 73% less CO2e than milk, "calculated from grower to grocer", and pointed viewers to a web page with the supporting report. The campaign drew 109 complaints. The ASA investigated five issues across TV, social and press ads and, on 26 January 2022, upheld four.

The 73% claim failed on scope, not on arithmetic.

Oatly's lifecycle data, calculated by CarbonCloud according to The Grocer, compared Oatly Barista Edition with whole cow's milk. The ASA said viewers would take the line to cover all Oatly products against any type of cow's milk, and the evidence didn't reach that far. A second claim, that the dairy and meat industries emit more CO2e than all the world's transport combined, was ruled misleading because the underlying figures counted different parts of each sector's life cycle.

Here is how the published claim compared with its evidence.

The boundary was the part Oatly got right, and it was stated on screen. The product and comparator were the parts that sank it. Oatly said afterwards that the claim should have named the Barista Edition and whole milk. And one claim survived: the statement that a global vegan diet would cut food's annual emissions by 6.6 billion tonnes, or 49%, was found to be substantiated.

5. Innocent Drinks: "Fix Up the Planet"

Innocent's 2021 animated ad, "Little Drinks, Big Dreams", showed cartoon characters singing about fixing up the planet alongside scenes of recycling. It attracted 26 complaints, one from the activist group Plastics Rebellion, which argued that a brand selling drinks in single-use plastic could not present purchase as good for the environment.

Its defence had two parts. It pointed to its B Corp certification, and it argued that the CMA's guidance allows businesses to talk about their environmental aspirations, which is what the ad was doing in a light-hearted way. The ASA disagreed in a ruling published on 23 February 2022. It concluded that viewers would read the ad as saying Innocent was environmentally friendly and that buying its products brought environmental benefits, and that Innocent had not shown this to be the case.

Company-level certification is not product-level evidence. Nor does a cheerful tone turn a claim into an aspiration.

6. Lufthansa's Absolute Claim

A Lufthansa poster seen in June 2022 showed the nose of an aircraft whose underside was a picture of Earth from space, with the words "Connecting the world. Protecting its future. #MakeChangeFly".

No complaint was needed: the ASA opened this case on its own initiative.

Lufthansa argued that the tagline was open to interpretation and that the ad linked to a campaign website explaining how the group was reducing its impact. The ASA's ruling of 1 March 2023 treated "protecting its future" as an absolute environmental claim, which the CAP Code requires to be backed by a high level of substantiation. It found no environmental initiative or commercially viable aviation technology that could support it, as Bloomberg reported.

A web link is not a qualification. If the headline claim can't stand on its own, pointing elsewhere won't rescue it.

7. KLM and Fly Responsibly

This one went to court. The Dutch foundation Fossielvrij brought a class action against KLM over 19 statements drawn from the Fly Responsibly campaign, the CO2ZERO product (which let passengers pay extra towards offsetting and sustainable aviation fuel) and marketing for KLM's Real Deal Days sale.

On 20 March 2024 the District Court of Amsterdam (ECLI:NL:RBAMS:2024:1512) found 15 of the 19 statements misleading and unlawful under Dutch law implementing the EU Unfair Commercial Practices Directive. The court said some statements relied on vague, general environmental benefits. Others painted too rosy a picture of sustainable aviation fuel and reforestation, which reduce aviation's impact only marginally (Osborne Clarke summary), and so created the impression that flying with KLM was sustainable.

For anyone selling offsets or low-carbon add-ons, the lesson is proportion: if a product addresses a small share of a customer's footprint, the marketing has to say so. [Editor: check whether either party appealed and the current status.]

8. ASOS, Boohoo and George at Asda

The CMA opened its first greenwashing investigation in July 2022. It looked at how three fashion retailers marketed clothing ranges as environmentally friendly, and closed the case on 27 March 2024 by accepting formal undertakings under Part 8 of the Enterprise Act 2002. There was no finding that any of the three had broken consumer law, which matters whenever the case is cited.

What makes the undertakings useful is their detail. The retailers committed to:

• make green claims that are accurate, in plain language and placed where shoppers can see them
• stop using natural imagery such as green leaves, or logos and icons, to suggest a product is greener than it is
• avoid ambiguous terms such as "eco" or "sustainable" when describing fabrics without substantiation
• put internal policies and staff training in place, build the policy into supplier due diligence, spot-check product listings and report progress to the CMA

On the same day the CMA sent an open letter to the whole fashion sector telling businesses to read the undertakings alongside the Green Claims Code. Outside fashion, they remain the most practical published benchmark for what the CMA expects a compliance process to look like.

9. DWS and the ESG Engine

Greenwashing isn't limited to consumer products.

On 25 September 2023 the SEC charged DWS Investment Management Americas (DIMA), a subsidiary of Deutsche Bank, over misstatements about its ESG investment process.

According to the SEC's order, DIMA marketed itself as a leader in ESG and described a proprietary "DWS ESG Engine" used across its investment teams. Between August 2018 and late 2021, the SEC found, DIMA failed to adequately implement parts of its own global ESG integration policy and lacked procedures to make sure its public statements about ESG-integrated products were accurate. Without admitting or denying the findings, DIMA agreed to a cease-and-desist order, a censure and a $19 million penalty. A separate $6 million penalty settled unrelated anti-money laundering charges.

DWS said at the time that the SEC had found no misstatements in its financial disclosures or fund prospectuses. [Editor: German proceedings against DWS were reported to have ended in a €25 million fine in 2025; confirm against the Frankfurt public prosecutor's announcement before adding.]

The UK equivalent risk now sits with the FCA. Its anti-greenwashing rule requires any reference to a product's or service's sustainability characteristics to be consistent with those characteristics and fair, clear and not misleading, and it applies to every authorised firm, banks and insurers included.

10. Keurig Canada's Recyclable Pods

Keurig Canada told customers its single-use K-Cup pods could be recycled once the lid was peeled off and the grounds emptied, and it made that claim on its website, on social media and on the pods and packaging.

Canada's Competition Bureau concluded in January 2022 that the claims were false or misleading wherever the pods weren't accepted for recycling. Outside British Columbia and Quebec, it found, municipal programmes didn't widely take them, and some that did required more preparation than Keurig described. Keurig reached an agreement with the Bureau under which it would:

1. pay a C$3 million penalty
2. donate C$800,000 to a Canadian environmental charity
3. pay C$85,000 towards the Bureau's investigation costs
4. change its recyclability claims and packaging, and publish corrective notices online, in the media, in new brewer packaging and by email to subscribers

A recyclability claim describes the collection system as much as the product. It is only true where the infrastructure exists.

11. Kohl's, Walmart and "Bamboo" Textiles

On 8 April 2022 the FTC, through the US Department of Justice, filed complaints against Kohl's and Walmart. Both retailers had marketed sheets, towels, bath rugs and other items as bamboo when the textiles were rayon. Rayon is made from cellulose, which may come from bamboo, using chemicals such as sodium hydroxide, and the FTC noted that cellulose manufacturing releases hazardous air pollutants. Both retailers had also described the products as made through eco-friendly processes.

The stipulated orders required Kohl's to pay $2.5 million and Walmart $3 million in civil penalties under the FTC's Penalty Offense Authority, and barred both from further deceptive green claims. According to the Department of Justice, as reported by FOX 13, both companies had received FTC letters in 2010 warning that advertising rayon as bamboo broke the rules. [Editor: confirm the 2010 warning letters against the DOJ release.]

A raw material can be green while the finished product isn't. Claims need to follow the processing, not stop at the source.

What the 11 Cases Have in Common

Strip away the sectors and five failure patterns remain.

The first two patterns account for most of the UK rulings. Both are data problems. A sustainability team that holds a clear record of its emissions boundary, the emissions factors it used and the share of activity each claim relates to is far better placed to write a claim that survives scrutiny.

Where the Rules Stand in September 2026

UK enforcement has more teeth than it did when most of these cases were decided. The CMA's direct powers under the Digital Markets, Competition and Consumers Act 2024 have applied since 6 April 2025, with penalties of up to the higher of £300,000 or 10% of global turnover. Its first investigations under those powers, announced in November 2025, focused on online pricing rather than green claims. [Editor: check for any CMA green claims case opened since.]

In the EU, Directive (EU) 2024/825 on Empowering Consumers for the Green Transition applies from 27 September 2026. It adds specific prohibitions to the Unfair Commercial Practices Directive, including generic environmental claims where the business can't demonstrate recognised excellent environmental performance, and claims that a product has a neutral, reduced or positive climate impact on the basis of offsetting. Penalties are set nationally. [Editor: confirm the Annex I point numbers and cite EUR-Lex directly.]

The separate Green Claims Directive is not law. It would have required third-party verification of explicit environmental claims before use, but the European Commission announced in June 2025 that it intended to withdraw the proposal and the final trilogue was cancelled. Sources disagree on whether the withdrawal has been formally completed. Treat it as stalled. [Editor: verify formal status on EUR-Lex or the Legislative Observatory.]

Checking a Claim Before It Goes Out

These cases point to a short sequence any team can run. It won't replace legal review for a significant campaign, and for non-broadcast ads the Committee of Advertising Practice offers a Copy Advice service for pre-publication checks.

1. Write down what a typical reader would take the claim to mean, then check whether your evidence covers that reading. This is where Oatly came unstuck.
2. State the scope in the claim itself: which product, site or entity, which period, which life cycle stages and which emissions scopes.
3. If the claim highlights a low-carbon part of the business, be ready to give its share of revenue, investment or activity in the same place.
4. Swap absolute and generic words (green, sustainable, eco, protecting the planet) for a specific, measured statement.
5. Where offsets, carbon credits or REGOs sit behind a claim, say so, and say what they do and don't cover.
6. Keep an evidence file: source data, the emissions factors and their version (for example, the DESNZ conversion factors for the relevant year), the calculation, and who signed it off.

More Information

For how emissions boundaries, scopes and conversion factors work, see Gaia's guide to carbon accounting.

• CMA, Guidance for businesses on making environmental claims (Green Claims Code), September 2021
• CMA, ASOS, Boohoo and Asda: greenwashing investigation (case page with undertakings and the open letter)
• FCA, FG24/3: Finalised non-handbook guidance on the anti-greenwashing rule
• ASA, Rulings on environmental issues

FAQs

What is a real example of greenwashing?

HSBC's 2021 bus stop posters are a clear UK example. They promoted up to $1 trillion of transition finance and a 2 million tree planting scheme, both of which HSBC could evidence. The ASA still ruled them misleading in October 2022 because they left out the bank's continued significant financing of high-emitting industries, which consumers would not know about.

Is greenwashing illegal in the UK?

Yes, where a claim misleads consumers it can breach consumer protection law, now set out in the Digital Markets, Competition and Consumers Act 2024. The CMA can fine businesses directly for breaches. Advertising claims also fall under the ASA's CAP and BCAP Codes, and FCA-authorised firms are bound by the anti-greenwashing rule. For a specific claim, take advice from a qualified lawyer.

Can the ASA fine a company for greenwashing?

No, the ASA cannot fine advertisers. It can rule that an ad breaches the CAP or BCAP Code, require it to be withdrawn or changed, and publish the ruling, which is often the more damaging outcome for a brand. The CMA, by contrast, can impose fines of up to 10% of global turnover under its direct enforcement powers.

What are the six principles of the Green Claims Code?

Claims must be truthful and accurate, clear and unambiguous, must not omit or hide important information, must make fair and meaningful comparisons, must consider the full life cycle of the product or service, and must be substantiated. The CMA published the code in September 2021 to show how existing consumer law applies to environmental claims.

What is the largest greenwashing penalty so far?

Volkswagen's "Clean Diesel" case produced the largest financial outcome, with the FTC reporting more than $9.5 billion repaid to US buyers, though that case also involved emissions test cheating. Among cases about ESG claims alone, the SEC's $19 million penalty against DWS in 2023 was widely reported at the time as the largest of its kind.

Is carbon offsetting a form of greenwashing?

Offsetting isn't greenwashing in itself, but claims built on it are under growing scrutiny. The Amsterdam court found KLM's offset-linked marketing misleading in 2024, and from 27 September 2026 EU rules prohibit claims that a product has a neutral, reduced or positive climate impact based on offsetting. Be precise about what an offset covers and what it doesn't.