The Secrets of Greenwashing - what changed after two years?

Two years ago, in August 2023, we published a short essay on the practice of greenwashing, focusing on the influence of this trend on the current state of the planet. The article mentioned several changes that were apparently underway or about to be implemented, with the aim of regulating environmental impact in the professional sector, especially in the case of large companies. Several months later, we wondered whether these projects had really taken off, and with what results. 

The main interest shown seems to focus on greater regulation of the approach to the entire environmental landscape, both from a concrete point of view, translated into decisions and actions aimed at reducing negative environmental impact, and from a more figurative point of view, such as putting a stop to the continuous and deceptive greenwashing carried out to avoid the obligation of transparency. The main recipients of what was shared were immediately identified as large enterprises, companies, corporations, and any industry responsible for a certain number of employees, production and, above all, consumption. The transparency required of participants in this scene is often completely ignored or, as has been seen in countless cases, replaced with a nice gift package wrapped in green. Aware that their consumption and results do not appear particularly appealing to customers and authorities, those responsible often hide behind words that smell of sea breeze, graphics reminiscent of an afternoon in the countryside, and emerald-coloured images that convince the reader that, after all, why would they omit the most important information, the actual data?

To address this considerable obstacle and protect consumers from greenwashing, even in 2023, the European Union proposed a new directive on the demonstration and communication of explicit environmental claims. Its aim is to make the environmental claims made by companies reliable, comparable and verifiable throughout the relevant territory, thereby contributing to the creation of a circular and green economy in Europe. To ensure that the claims in question comply with the requirements, specific and proven details are needed regarding the materials, production processes and certifications held by the entity in question. The proposed change would enable consumers to make informed purchasing choices and, above all, could establish a level playing field in terms of the environmental performance of products. The proposal made in 2023 is still under negotiation, but an agreement should be reached by the end of 2025. However, the general opinion seems to be concerned about the impact of these new regulations, mainly due to the rather demanding requirements relating to the possible verification of environmental claims by third parties.

The effort required of companies doesn't end there. The environmental claims in question are not limited to what has been shared so far, but also include the entire issue of carbon emissions. We defined carbon offsetting as the pinnacle of greenwashing in our 2023 article, and considering the measures taken in this regard, we are not the only ones who think so. Nowadays, it is explicitly required that statements relating to carbon offset be as accurate as possible and communicated with the utmost transparency; for example, by making public the carbon footprint of one's business, the percentage offset and the specific offset projects used. Unfortunately, the latter are often presented as a foolproof solution, but the amount of carbon they save is often overestimated. To address these frequent inaccuracies, companies are now required to clearly explain the limitations of offsetting, while focusing on reducing emissions themselves, as well as offsetting them. Needless to say, the environmental claims in question include any official communication made publicly. This means that slogans, advertisements and promotional projects relating to sustainability must be considered long-term commitments and not temporary marketing solutions. Any campaign on this subject must therefore be supported by sufficient evidence behind each claim.

As far as the Italian legal landscape is concerned, failure to comply with the directive may result in criminal implications; according to some legal interpretations, it could also fall under the category of “commercial fraud”, which carries a prison sentence of up to two years or fines. The relevant authority is the AGCM, the Italian Competition and Market Authority.

The situation in the United Kingdom is similar. The relationship between companies and environmental protection is mainly governed by two reference texts: the Green Claims Code and the DMCC Act of 2024 (Digital Markets, Competition and Consumers Act). The first consists of a short list defining six key points for verifying that the environmental claims made by those directly involved are truly ecological and aimed at protecting the environment. The second is of a legal nature, as it is an “act” and therefore primary legislation approved by the British Parliament, and came into force on 6 April 2025. The implementation of this law has given the relevant authority, the CMA (Competition & Markets Authority), the power to take more severe enforcement action against companies that do not comply with the rules, including the possibility of imposing financial penalties of up to 10% of the company's global turnover or £300,000, whichever is greater. Until the beginning of the year, the worst consequence of greenwashing was simply negative publicity and slight damage to reputation, but the current state of affairs translates into potential considerable economic damage.

The consequence of this general stance by European authorities to protect consumers from misleading environmental claims has been a wave of lawsuits against greenwashing across all industrial sectors between 2024 and 2025. Shein, ASOS, Coca-Cola and KLM are just some of the companies accused in recent years, true giants within their respective industries. In addition, with the rapid development of artificial intelligence systems, several tech companies could soon be added to the list of companies under investigation. The technology in question has often been used as a tool to identify greenwashing in the actions, advertising or otherwise, of third parties; cutting-edge AI systems are now able to compare public statements with actual environmental data, identifying discrepancies between claims and actual real-world performance indicators, such as energy consumption or emissions.

Nevertheless, all that glitters is not gold. Artificial intelligence is imperfect, prone to “hallucinations” and often trained on incorrect data and information, thus risking triggering real storms of misinformation, making the whole situation even more complex. The most worrying aspect of using AI in this context, however, is the huge energy consumption of the technology itself: the computing power required to train the models in question can require a terrifying amount of electricity, inevitably followed by an increase in CO2 emissions. In addition, cooling the machinery involved in the aforementioned training requires a large amount of water, which can put a strain on water resources and ecosystems in the surrounding areas. To give an idea of the impact, according to an analysis conducted in 2024 by the IEA (International Energy Agency), a simple request to ChatGPT consumes about 10 times more electricity than a Google search. By 2026, it is estimated that the electricity consumption of data centres will approach approximately 1,050 terawatts, and considering the pace at which companies are building new similar buildings, very soon most of the electricity needed to power them will have to come from fossil fuel-fired power plants. Furthermore, these centres produce significant amounts of electronic waste containing hazardous substances, such as mercury and lead, placing an additional burden on the environment.

In conclusion, in 2025, how can we categorise and verify companies' commitment to the ecological landscape? How can consumers identify which companies deserve their financial support and, above all, their trust? The true value of companies is determined by ESG, the Environmental, Social and Governance assessments that provide a comprehensive view of the impact of the choices made and the projects undertaken. In 2025, the challenges associated with adapting to ESG practices mainly concern the standardisation of metrics and the transparency and accuracy of the data shared. In addition, the entire approach to ESG currently includes a certain focus on issues such as inclusion, equity and diversity, including at the supply chain level, and high-tech and cleantech innovation aimed at adapting to ongoing climate change. The objectives set by ESG include achieving “carbon neutrality”, i.e. the ability to reduce CO2 emissions and create conditions that allow them to be reduced to zero, and meeting the criteria set out in the 17 Sustainable Development Goals established in the 2030 Agenda for Sustainable Development. Considering a company's ESG rating can be the first step in understanding the level of environmental commitment undertaken by that company.