Green Marketing Rules: How Firms Can Cut Fine Risk

Reviewing green marketing claims is not solely the responsibility of sustainability or legal departments. From product packaging and online shop descriptions to social media, any communication suggesting that a product, service or business has a positive environmental impact may pose a risk.

According to a statement by the Hungarian Competition Authority, the Hungarian legislation transposing the EU rules entered into force on 27 September 2026. The safest approach for companies is therefore to review every green claim in the same way as any other product promise that may influence a consumer’s decision.

General green terms cause the most problems

Terms such as “environmentally friendly”, “green”, “eco”, “sustainable” or “climate-friendly” do not in themselves explain precisely which characteristic they refer to or what comparison they are based on. Directive (EU) 2024/825 regulates the use of generic environmental claims and amends the EU directives on unfair commercial practices and consumer rights.

A claim does not become sufficiently precise simply because it is accompanied by a green leaf, a globe or a nature photograph. The visual presentation, slogan and additional explanation together shape the overall impression created in the consumer’s mind. If the main message is too broad, a hard-to-find footnote may not necessarily clarify it.

Twelve new practices have been added to the blacklist

According to official information from the Hungarian Competition Authority, 12 new items have been added to the so-called blacklist in the annex to the Act on Unfair Commercial Practices against Consumers. For conduct listed there, the authority may establish an infringement without carrying out a separate assessment of its impact on consumers.

This is an important change in risk management. A business should not assume that an inaccurate environmental claim reached few customers or probably misled no one. For blacklisted practices, the contested conduct itself may provide grounds for finding an infringement.

Carbon neutrality is a particularly sensitive claim

Under the EU directive, a product cannot be claimed to have a neutral, reduced or positive impact in terms of greenhouse gas emissions if the claim is based solely on emissions offsetting. Particularly thorough legal and professional review is therefore warranted before using statements such as “carbon-neutral product”.

Reducing emissions from a company’s own manufacturing process is not the same as purchasing an offset implemented elsewhere. Marketing materials must clearly distinguish between actual emissions reductions, a stated future target and offsetting. A commitment must not be presented as an achievement that has already been made.

ESG reporting and consumer advertising are not the same

Corporate ESG reports and green marketing communications aimed at consumers serve different purposes. A company may meet its applicable ESG reporting obligations, but this does not automatically make an environmental claim on product packaging or in an advertisement lawful.

When assessing consumer communications, what matters is the message received by the average buyer. Group-level data in a corporate sustainability report does not necessarily support a promise concerning a single product. Marketing professionals must therefore specifically link the subject and scope of the claim to the evidence supporting it.

How to make an environmental claim more precise

Suitable wording is not necessarily more striking, but narrower and more verifiable. Instead of “green packaging”, it is advisable to clarify which component and characteristic of the packaging the claim concerns and under what conditions it applies. However, specific wording can only be used if the business holds data that substantiates it.

• Define the subject of the claim: does it concern the entire product, the packaging, raw materials, manufacturing or transport?
• Do not hide the limitations: material conditions should appear close to the claim and be presented clearly.
• Avoid unjustified superlatives: statements such as “the greenest” or “the most sustainable” involve a comparison and therefore require a precise benchmark.
• Separate facts from targets: current performance should not be confused with a future commitment.
• Review the overall impression: assess not only the wording but also the images, icons, colours and highlighted elements.

Every claim should be backed by organised evidence

According to a professional summary by Gross Office, companies should compile a separate “evidence file” for every green slogan. This may be internal documentation that makes it possible to determine retrospectively who approved the claim, when it was approved and which data supported it.

The file may include the measurement method used, the period assessed, the basis of comparison, supplier verification, the scope of a certificate and any limitations. The document must genuinely relate to the same product and the same characteristic highlighted in the advertisement. A general corporate target does not replace evidence supporting a specific product claim.

Retailers cannot automatically copy everything either

According to the Gross Office analysis and a report by Portfolio, resellers and retailers may also face consumer protection risks if they repeat unsubstantiated green advertising claims made by manufacturers. A ready-made product description received from a supplier should therefore not automatically be treated as verified content.

Online shops and retail chains should request the precise meaning of a claim and the evidence supporting it. The same applies to wording supplied to agencies, partners and influencers: an abbreviated version must not distort the original, verifiable message.

Older product descriptions should also be reviewed

Professional reports have differed on how products manufactured before the rules entered into force should be treated. According to a September 2026 report by Zöld Hang, a late amendment removed the restriction linked to the manufacturing date, meaning that green claims concerning goods already on the market must also be reviewed.

To reduce risk in practice, it is therefore not enough to review only new campaigns. Companies should take an inventory of packaging, product pages, advertisements, marketplace listings and social media templates, then review the broadest and strongest claims first.

Complete silence is not the answer

According to an analysis by the Hungarian Marketing Association, fear of sanctions may intensify “greenhushing”, meaning that companies choose not to communicate their sustainability achievements. This may reduce the risk associated with certain advertising claims, but it may also discourage companies from presenting genuine, verifiable progress.

The safer path is not necessarily silence, but more precise communication. Businesses should promise less, clearly state the scope of each claim and publish only achievements supported by up-to-date evidence.

Practical checklist for business leaders and marketers

• Create a shared register of all environmental claims and where they are used.
• Assign a responsible person, supporting evidence and a review date to every claim.
• Complete legal, technical and marketing reviews before approving a campaign or packaging.
• Request documentation for supplier claims and check its material, geographical and temporal scope.
• Do not extend a certificate to a product or characteristic that it does not cover.
• Clearly present a future commitment as a target, not as an achievement already made.
• Apply amended claims across all channels, including older product pages and partner content.

Compliance always depends on the wording of the claim, the context in which it appears and the evidence supporting it. The most important tools for avoiding greenwashing are precise wording, consistent internal approval and traceable documentation. This information does not constitute a legal opinion; for uncertain or high-risk campaigns, it is advisable to consult a professional with expertise in consumer protection law.