Dr. Fawzy Younis: Greenwashing Exposed.. When “Green” Becomes a Marketing Illusion

As consumer awareness of climate change and sustainability grows, being labeled “eco-friendly” has become a powerful competitive advantage for products and services.

But marketing can sometimes move faster than reality.

That gap has given rise to what is known as greenwashing: a polished environmental promise on a package, website, or advertisement, while the underlying production processes and environmental impacts remain largely unchanged.

Greenwashing is no longer simply a matter of misleading advertising. It has become a growing concern for consumers, regulators, investors, and genuinely sustainable businesses.

This article examines what greenwashing is, how it works, why companies use it, what scientific research says about its scale and impact, and how recent regulatory developments in Europe and the United Kingdom are changing the rules.

It also offers a practical guide to identifying greenwashing and explains what these changes mean for exporters in Egypt and across the Arab region.

What Is Greenwashing?

Greenwashing refers to misleading practices through which companies or other organizations create a false, exaggerated, or insufficiently substantiated impression that their products, services, or activities are environmentally friendly.

The objective may be to attract consumers who care about sustainability without making equivalent changes to the company’s actual environmental performance.

Greenwashing can take verbal, visual, or strategic forms.

A company may use vague environmental language, attractive images of nature, selective information, questionable labels, or isolated environmental initiatives to create an overall impression of sustainability that is not supported by the evidence.

The term is generally traced to 1986, when American environmental activist Jay Westerveld used it in an essay criticizing hotels that encouraged guests to reuse towels “to protect the environment,” while the practice also reduced laundry costs and was not accompanied by broader changes to the hotels’ environmental practices.
The Most Common Forms of Greenwashing

1. Vague Environmental Language

One of the most common techniques is the use of broad and poorly defined expressions such as:

• “eco-friendly”
• “green”
• “natural”
• “sustainable”
• “environmentally safe”

The problem is not necessarily the words themselves, but the absence of a clear definition, scope, measurement, or evidence behind them.

Recent EU rules place significant restrictions on generic environmental claims when companies cannot substantiate them through recognized environmental performance.

2. Visual Greenwashing

Green colors, leaves, forests, flowers, clean landscapes, and other natural imagery can create an immediate association with environmental responsibility.

But visual appearance is not evidence of environmental performance.

A package may look green without the product itself being demonstrably better for the environment.

3. Hiding or Distracting from Negative Impacts

Another common strategy is to highlight a small environmental benefit while leaving the larger environmental footprint unmentioned.

For example, a company may promote a recyclable component of its packaging while providing little information about emissions, raw materials, manufacturing, transportation, or end-of-life impacts.

This is why environmental claims increasingly need to be assessed across the full life cycle of a product, rather than on the basis of one isolated feature.

4. Fake or Misleading Certifications

Some products display seals, logos, or symbols that resemble independent environmental certifications but are actually created internally or lack a credible verification system.

The proliferation of such labels can make it difficult for consumers to distinguish genuine third-party certification from marketing imagery.

The EU’s new rules place greater restrictions on environmental labels that are not based on recognized certification systems.

5. Selective Environmental Justification

A company may announce a limited environmental initiative—such as planting trees—and use it to support a much broader claim about the sustainability of its operations.

The existence of an environmental project does not automatically make an entire product, company, or supply chain environmentally sustainable.

Claims about future environmental performance also require credible commitments, implementation plans, and time-bound objectives.

Why Do Companies Greenwash?

Several factors can encourage greenwashing.

Exploiting Growing Consumer Awareness

As more consumers seek products that are environmentally responsible, sustainability has become an increasingly valuable marketing attribute.

Improving Corporate Image

Creating the appearance of environmental responsibility can be considerably easier and cheaper than transforming production systems, energy use, supply chains, materials, and waste management.

Increasing Sales and Market Share

Environmental claims can help companies reach consumers who are actively looking for sustainable alternatives.
But the damage does not stop with consumers.

When unsupported environmental claims are rewarded by the market, companies that genuinely invest in sustainability may be placed at a competitive disadvantage.

The absence of clear and consistent rules can therefore distort competition as well as consumer choice.

What Does the Scientific Evidence Say?

The Scale of the Problem

A European Commission study published in 2020 found that 53.3% of the environmental claims examined were vague, misleading, or insufficiently substantiated, while 40% had no supporting evidence.

The Commission also found significant weaknesses in the verification of environmental labels.

These findings helped reinforce the case for stronger rules governing environmental claims in the European market.

The Trust Problem

Research has also identified an important consequence of greenwashing: loss of trust.

A well-known study by Chen and Chang found that greenwashing can undermine green trust by increasing consumer confusion and perceived environmental risk.

More recent reviews suggest that the relationship between greenwashing and purchasing behavior is more complex than simply “greenwashing reduces sales.”

Consumer trust and perceived value can increase green purchase intentions, while perceived risk can reduce them.

In other words, the damage caused by greenwashing may operate indirectly: misleading claims can increase uncertainty, weaken trust, and make consumers less confident about distinguishing genuinely sustainable products from those that merely appear sustainable.

The Other Side: Greenhushing

There is also a less visible phenomenon known as greenhushing.

As scrutiny of environmental claims increases, some companies may become reluctant to communicate genuine environmental achievements for fear of being challenged over the accuracy or scope of their claims.

The policy challenge, therefore, is not simply to prevent misleading green claims. It is also to create a market in which companies can communicate genuine environmental progress with confidence—as long as their claims are transparent, proportionate, and supported by evidence.

The broader systemic risk is clear: if misleading environmental claims are rewarded, capital and consumer demand may be diverted away from genuine solutions, while the trust required for effective climate action is gradually eroded.

The Law Tightens Around Greenwashing

The European Union: Directive 2024/825

One of the most important recent developments is the European Union’s Directive (EU) 2024/825 on empowering consumers for the green transition.

The directive was published on March 6, 2024, and entered into force on March 26, 2024.

EU Member States were required to transpose it into national law by March 27, 2026, and its provisions began to apply on September 27, 2026.

The directive introduces a number of important restrictions on environmental marketing and consumer information.

Generic Environmental Claims

The rules restrict certain generic environmental claims when companies cannot demonstrate the recognized environmental performance necessary to substantiate them.

This means that terms such as “green,” “eco-friendly,” and similar broad claims can no longer simply be used as attractive marketing language without an appropriate basis.

Future Environmental Performance Claims

Companies making claims about future environmental improvements must be able to support those claims with clear and objective commitments, implementation plans, and time-bound targets.

The shift is significant: a promise about the future increasingly needs to be accompanied by a credible roadmap for delivering it.

Environmental Labels

The directive also restricts the use of environmental sustainability labels that are not based on recognized certification schemes.

This is intended to reduce consumer confusion in a market increasingly crowded with environmental symbols and sustainability claims.

Climate Neutrality and Carbon Offsetting

The directive also addresses claims suggesting that a product has a neutral, reduced, or positive climate impact when such claims are based on offsetting greenhouse-gas emissions outside the product’s value chain.

This distinction is important.

It does not mean that companies cannot support carbon-removal or other environmental projects. Rather, companies cannot automatically use such external compensation to portray the product itself as having a particular climate impact that the underlying product life cycle does not demonstrate.

What About Products from Outside the EU?

The rules are particularly important for companies selling to EU consumers.

Therefore, an Egyptian or Arab company exporting consumer products to Europe cannot assume that environmental claims used in its domestic market will remain irrelevant once the product enters the EU market.
The key question is not where the company is headquartered, but whether its commercial practices fall within the scope of the EU consumer-protection rules.

The Proposed Green Claims Directive

The Green Claims Directive is a separate legislative initiative and should not be confused with Directive 2024/825.

The European Commission proposed the legislation in March 2023 to establish more detailed rules for voluntary environmental claims, including requirements concerning scientific substantiation and verification.
However, negotiations encountered major difficulties in 2025.

The Commission announced its intention to withdraw the proposal in June 2025, while subsequent institutional developments indicated that the file had not simply disappeared from the EU policy agenda.

Its final legislative status therefore remains distinct from the already applicable Directive 2024/825.
For businesses, the practical lesson is simple: Directive 2024/825 is already part of the regulatory landscape, while the proposed Green Claims Directive should not be treated as an equivalent, currently applicable law.

The United Kingdom

The United Kingdom has also developed a framework for addressing misleading environmental claims.
The Competition and Markets Authority (CMA) published its Green Claims Code in 2021, setting out six core principles for environmental claims.

Among other requirements, environmental claims should be:

• truthful and accurate;
• clear and unambiguous;
• supported by evidence;
• based on fair comparisons;
• transparent about important information; and
• assessed in the context of the full life cycle of the product or service.

The Digital Markets, Competition and Consumers Act 2024 strengthened the CMA’s consumer-enforcement powers.

Under the new regime, the CMA can impose significant penalties for certain consumer-law violations, including fines of up to 10% of a company’s global annual turnover in applicable cases.

The UK’s Advertising Standards Authority has also continued to issue rulings concerning misleading environmental advertising, reinforcing the broader trend toward evidence-based green claims.

International Standards: ISO 14021, ISO 14024 and ISO 14025

International standards provide another layer of guidance.

The ISO framework distinguishes among different forms of environmental labeling and declarations.
ISO 14024 addresses Type I environmental labeling programs, generally involving independent third-party assessment.

ISO 14021 covers self-declared environmental claims made by organizations.

ISO 14025 concerns Type III environmental declarations, including Environmental Product Declarations (EPDs).

The updated ISO 14021:2026 strengthens the framework for self-declared environmental claims, including requirements related to documented programs, supporting information, and transparent and scientifically based evaluation methods.

For businesses, this represents an important shift: an environmental claim should increasingly be treated as a statement that requires an evidence trail, rather than simply a marketing slogan.

Greenwashing Rules at a Glance

Jurisdiction / Framework Instrument Current Position

European Union Directive 2024/825 Applicable since September 27, 2026

European Union Proposed Green Claims Directive Legislative process disrupted; status requires monitoring
United Kingdom CMA Green Claims Code + 2024 Act Stronger enforcement powers and potentially substantial fines

International ISO 14021 / 14024 / 14025 Voluntary international standards; ISO 14021 updated in 2026
How Can Greenwashing Be Detected?

1. Research the Claim

When a company says that a product is “green” or “eco-friendly,” ask a simple question:

According to what measurement?

Look for data, percentages, methodologies, time periods, and clearly defined boundaries.

2. Look Beyond the Green Packaging

Trees, leaves, forests, water, and green colors may communicate an environmental message, but they do not prove environmental performance.

The evidence matters more than the artwork.

3. Read the Fine Print

Ask whether the claim applies to:

• the entire product;
• the packaging only;
• the manufacturing process;
• one specific ingredient;
• a particular stage of the life cycle; or
• the product’s entire life cycle.

A claim can be technically true while still creating a misleading overall impression if important context is omitted.

4. Check Who Verified It

Look for recognized independent certification systems rather than relying on logos created by the company itself.
And even where a certification exists, consumers should check what exactly it certifies and what its criteria cover.

5. Look at the Whole Picture

If a manufacturer says it reduced energy consumption by 20%, that is a specific and potentially verifiable claim.
But that does not automatically mean the entire company or product is “environmentally friendly.”
The broader environmental footprint still matters.

Five Preventive Steps for Companies and Exporters

1. Avoid Generic Claims You Cannot Prove

Do not describe a product as “sustainable,” “green,” or “eco-friendly” unless you can clearly define what the claim means and substantiate it.

2. Connect Every Claim to Evidence

Environmental claims should be supported by specific figures, credible sources, and a clearly stated measurement methodology.

3. Use Independent Certification Where Appropriate

Recognized third-party certification can provide stronger assurance than internally designed environmental seals.

4. Measure Before Making Climate Claims

Calculate the relevant carbon footprint using a recognized methodology before making claims about climate performance.
Do not assume that purchasing offsets alone makes a product “carbon neutral.”

5. Build an Evidence File

Companies should document the data, assumptions, methodologies, boundaries, dates, and verification procedures behind every significant environmental claim.

This creates an evidence trail that can withstand scrutiny from customers, regulators, auditors, investors, and business partners.

What Does This Mean for Egypt and the Arab Region?

The implications for Egyptian and Arab exporters are becoming increasingly practical.

If a product is marketed to consumers in the European Union, environmental claims appearing on its packaging, website, advertising, or other consumer-facing communications may need to comply with the applicable European rules.

For exporters, this means reviewing phrases such as:

• “eco-friendly”
• “green”
• “sustainable”
• “low-carbon”
• “carbon neutral”
• “climate positive”

and asking whether each statement can be supported by measurable and independently defensible evidence.

This issue also intersects with the broader transformation of international trade toward greater carbon and environmental transparency, including the EU’s Carbon Border Adjustment Mechanism (CBAM).

The direction of travel is clear: environmental performance is increasingly becoming a trade-related data issue rather than merely a branding issue.

For Egyptian and Arab businesses, this creates both a compliance challenge and a potential competitive opportunity.

Companies that invest early in carbon-footprint measurement, environmental data, supply-chain transparency, life-cycle assessment, and credible verification may be better positioned to meet increasingly demanding international markets.

It also creates opportunities for universities, research centers, startups, consultants, and civil-society organizations to build capabilities in carbon accounting, environmental verification, life-cycle assessment, and sustainability data.

The End of “Green Perfection”?

The era in which environmental marketing could rely primarily on attractive language and imagery is coming under increasing scrutiny.

The emerging equation is built around three mutually reinforcing forces:

consumer vigilance, regulatory enforcement, and corporate transparency.

But transparency should not mean pretending that a company is perfect.

It should mean being able to say what has improved, what has not improved, how performance was measured, what remains uncertain, and what the company plans to do next.

The green economy ultimately needs more than green marketing.
It needs green evidence.

And the simplest rule for consumers, businesses, and investors remains: Do not be fooled by the color green. Always look for the data.