The Evolution of Greenwashing

Posted on 27th May 2026

An industrial facility overlaid with green paint and nature imagery, illustrating the concept of greenwashing

From hotel towel cards to billion-pound fines – how greenwashing grew from a niche PR tactic into one of the most closely scrutinised risks in modern business.

What Is Greenwashing?

Greenwashing is the practice of making misleading, exaggerated, or unsubstantiated claims about the environmental credentials of a product, service, or organisation. It ranges from the deliberate to the inadvertent, but the outcome is the same: consumers and investors are misled, genuine sustainability efforts are undermined, and trust in green claims erodes.

A Brief History

The term ‘greenwashing’ was coined in 1986 by American environmentalist Jay Westerveld, who noticed a hotel urging guests to reuse towels to “save the environment” whilst simultaneously expanding its resort into ecologically sensitive land. The messaging, he argued, was not genuine commitment, it was a veneer.

Through the 1990s, environmental marketing went mainstream. DuPont ran ads celebrating its oil tankers with images of dancing dolphins (at the time it was the single largest corporate polluter in the United States), while Chevron’s “People Do” campaign showcased wildlife habitats whilst the company lobbied against environmental regulation.¹ The era also saw a proliferation of voluntary eco-labels with no independent verification, and vague terms like “all-natural” and “eco-friendly” appearing on everything from cleaning products to cars.

By the 2000s and 2010s, cases were making headlines at scale. Volkswagen’s Dieselgate scandal, in which software made diesel cars appear compliant during emissions testing whilst emitting up to 40 times the legal limit on the road, cost the company over €30 billion.² The ASA (Advertising Standards Authority) banned HSBC adverts for promoting green financing pledges without disclosing the bank’s continued financing of fossil fuel projects.³

How to Spot It

The most common greenwashing tactics to watch for:

Vague language: “eco-friendly,” “sustainable,” or “natural” without definition or evidence
Selective disclosure: highlighting one green credential whilst staying silent on significant harms elsewhere
Offsetting as a headline claim: describing a product as “carbon neutral” without explaining the role and quality of offsets used
Irrelevant claims: advertising that a product is “CFC-free” when CFCs have been banned for decades
Unverified certifications: logos implying third-party endorsement that are self-created or unaudited
Green aesthetics without substance: nature imagery and earthy colour palettes used to imply responsibility without any actual claim

The UK Regulatory Landscape

The regulatory environment has hardened considerably, and businesses can no longer treat greenwashing primarily as a reputational risk.

The CMA (Competition and Markets Authority) published its Green Claims Code in 2021, establishing that claims must be truthful, unambiguous, substantiated, and not misleading by omission. The FCA’s anti-greenwashing rule came into force in May 2024, requiring all authorised firms to ensure sustainability claims are fair, clear, and not misleading, with naming and marketing restrictions on investment products following in December 2024.

The most significant change arrived on 6 April 2025, when the consumer-protection provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) came into force. The CMA can now directly investigate and fine companies up to 10% of global annual turnover, or £300,000 (whichever is greater) without going to court.⁴ Crucially, liability does not require intent: an unwitting breach is still a breach.⁵ The CMA and ASA operate under a formal Memorandum of Understanding, meaning ASA advertising rulings can feed directly into CMA enforcement action.⁶

Early enforcement is expected to focus on objectively false claims and systemic governance failures, but all environmental claims remain in scope.

Practical Guidance for Businesses

The principles for staying on the right side of this issue are clear:

Be specific. “Made with 30% recycled content” is more defensible than “eco-friendly packaging.” Precision both reduces risk and builds consumer trust.
Substantiate before you publish. Every claim should be backed by documented, verifiable evidence available for regulatory review. Do not rely on supplier assurances without your own due diligence.
Disclose the full picture. Do not promote environmental benefits whilst omitting material negatives. Regulators treat misleading omissions the same as misleading statements.
Take particular care with net zero and carbon neutral claims. Any claim based on offsetting must clearly explain the standards those offsets meet and the direct emissions reductions that underpin the claim.
Establish internal governance. Green claims should not be drafted and published by marketing teams alone. A formal review process involving sustainability, legal, and compliance sign-off significantly reduces exposure.
Keep claims under review. Evidence bases become outdated. A claim that was accurate when made can become misleading as standards, methodologies, or a company’s own practices change.

How 2EA Can Help

2EA helps organisations build the evidence base behind their environmental claims — from carbon footprinting and net zero strategy to sustainability reporting and green claims compliance reviews. Get in touch to find out more.

Sources & Further Reading

[1] TerraChoice, The Seven Sins of Greenwashing (2010): trellis.net/resource/sins-greenwashing-home-and-family-edition-2010/

[2] Transport & Environment, Dieselgate: A Timeline (2020): transportenvironment.org/articles/dieselgate-who-what-how

[3] ASA, rulings on HSBC advertising campaigns (2022–2023): asa.org.uk/rulings/hsbc-uk-bank-plc-g21-1127656-hsbc-uk-bank-plc.html

[4] White & Case, Supply Chain Green Claims: CMA Signals Enforcement Escalation (February 2026): whitecase.com/insight-alert/supply-chain-green-claims-uk-cma-signals-enforcement-escalation

[5] Fieldfisher, Greenwashing Under Scrutiny: The CMA’s New Powers (May 2025): fieldfisher.com/en/insights/greenwashing-under-scrutiny-the-cma-s-new-powers-to-tackle-misleading-environmental-claims

[6] Stephenson Harwood, Greenwashing — Now Is the Time to Get It Right (October 2024): stephensonharwood.com/insights/greenwashing-now-is-the-time-to-get-it-right-warns -the-cma-new-guidance-issued/