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December 30, 2025
December 30, 2025

Make Ethical Sustainability Claims Without Greenwashing

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Sustainability claims for manufacturers are increasingly treated as regulated statements, not marketing language. As scrutiny around greenwashing intensifies, even well-intentioned environmental claims can create regulatory, reputational, and commercial risk if they are vague, overstated, or poorly substantiated.

Under the Ecodesign for Sustainable Products Regulation (ESPR) and the proposed EU Green Claims Directive, manufacturers are required to clearly define what a sustainability claim refers to, support it with reliable evidence, and present it without misleading emphasis. This means manufacturer sustainability claims must be accurate, verifiable, and proportionate to actual performance.

This guide outlines how manufacturers can make clear, transparent, and substantiated sustainability claims, helping organisations communicate impact responsibly, avoid greenwashing, and build trust with regulators, customers, and supply-chain partners.

What Greenwashing Is (and Why Manufacturers Get Caught)

Greenwashing occurs when a company makes sustainability claims that sound good but are unclear, inaccurate, or not fully supported by facts. This often involves using vague terms like “green” or “eco-friendly,” highlighting minor improvements, or omitting crucial details about environmental impact. 

Manufacturers are more likely to get caught because their operations and supply chains are complex, and sustainability information can be hard to track and explain. As regulators and customers expect greater transparency, unclear or incomplete claims are more likely to be questioned.

As scrutiny increases, market surveillance authorities are paying closer attention to how sustainability claims are presented, particularly where claims lack evidence, clarity, or consistency across products and markets.

Common manufacturing-specific pitfalls include:

  • Vague wording: “eco-friendly,” “sustainable,” or “low impact” without defining what that means
  • Absolute statements: “100% sustainable,” “zero impact,” or “fully circular”
  • Missing proof: Claims that are not linked to audits, measurements, or third-party documentation
  • Unclear scope: Not specifying whether the claim applies to a product, component, site, or process
  • Outdated data: Using old figures while implying current performance

These gaps expose manufacturers to greenwashing allegations even when real sustainability work is underway.

Principles for Communicating Sustainability Responsibly

Responsible sustainability communication is grounded in accuracy, transparency, and proportionality. Key principles include:

  • Be specific about what has changed, improved, or been measured
  • Match the claim to the evidence, not the ambition
  • Disclose boundaries and assumptions clearly
  • Avoid absolutes unless they are demonstrably true
  • Update claims as data evolves, not just marketing cycles

When claims are treated as structured information rather than creative copy, greenwashing risk drops significantly. As sustainability reporting requirements expand under the Corporate Sustainability Reporting Directive (CSRD), the data companies disclose publicly, increasingly becoming the reference point for external sustainability claims. Claims that are inconsistent with reported performance, or that selectively highlight improvements, can undermine credibility and attract regulatory attention.

Sustainability Messaging Checklist (Anti-Greenwashing)

Before publishing any sustainability claim, manufacturers should be able to answer:

  • What exact product, process, or site does this claim apply to?
  • What metric or standard supports it?
  • What is the baseline and time period?
  • Is the claim current and still accurate?
  • Could a regulator, customer, or auditor verify this claim independently?

If any answer is unclear, the claim needs refinement.

Avoid Common Pitfalls That Slip Into Greenwashing

Even well-meaning teams often introduce risk through:

  • Marketing language that goes beyond operational reality
  • Claims copied across channels without context (website, packaging, tenders)
  • Sustainability targets presented as achieved outcomes
  • Selective disclosure of positives while ignoring material trade-offs

Avoiding these pitfalls requires coordination between sustainability, compliance, and marketing teams, not just better copywriting.

Align With ESPR and Related “Green Claims” Expectations

The Ecodesign for Sustainable Products Regulation (ESPR) raises the standards for how sustainability information is communicated, especially at the product level.

At a high level, ESPR signals that:

  • Sustainability information must be clear, specific, and substantiated
  • Claims should be linked to product data, not generic brand statements
  • Misleading presentation, through omission, exaggeration, or lack of context, is unacceptable

This shifts sustainability claims from marketing statements to regulated product information.

How ESPR Strengthens Product-Level Sustainability Information Through Digital Product Passports

The Ecodesign for Sustainable Products Regulation (ESPR) promotes  Digital Product Passports (DPPs) as a mechanism for delivering clear, structured, and traceable product-level sustainability information. 

Instead of relying on broad environmental claims, DPPs connect sustainability statements directly to verifiable product data, such as material composition, environmental performance indicators, durability information, and compliance attributes. This marks a shift from narrative sustainability messaging to data-driven transparency for manufacturers. 

Sustainability claims are increasingly expected to reflect specific, up-to-date product information that can be shared consistently across regulatory, commercial, and supply-chain contexts. By standardising how sustainability data is recorded and accessed, DPPs help improve comparability, reduce ambiguity, and support more credible, defensible sustainability claims across a product’s lifecycle.

DPP Turns Claims Into Verifiable, Structured Product Data

Instead of free-text claims, DPPs connect statements to:

  • Defined data fields
  • Evidence documents
  • Version history and ownership

This fundamentally changes how claims are created and managed.

Green Claims Expectations: Clarity + Substantiation + No Misleading Presentation

For manufacturers, this means:

  • Writing claims that can be mapped to data
  • Avoiding broad environmental benefit statements
  • Presenting sustainability performance in a balanced, factual way

Use DPP to Make Claims Verifiable (and Reduce Greenwashing Risk)

Digital Product Passports allow manufacturers to operationalise ethical claims rather than relying on static statements.

Convert Each Claim Into a DPP Field or Data Point

Every sustainability claim should correspond to a specific data attribute, such as recycled content percentage, energy intensity, or certification status.

Link Every Claim to a Source Document

Claims should reference:

  • Test reports
  • Certifications
  • Supplier declarations
  • Internal audits

This ensures claims remain defensible.

Version Control, Date Stamps, and Ownership

DPPs make it clear:

  • When was the data last updated
  • Who owns the claim
  • Which version is currently valid

This prevents outdated or conflicting claims from circulating.

Put a Simple Internal Workflow in Place (So Claims Stay Consistent)

Ethical sustainability communication depends on governance, not complexity.

A Lightweight Process for Manufacturers

  • Claim library: Approved, standardised wording
  • Evidence folder: One proof source per claim
  • Review and sign-off: Sustainability + legal/compliance
  • Revalidation schedule: Regular checks tied to data updates

Sync Updates Across All Channels

When a claim changes, it must update consistently across:

  • Marketing materials
  • Sales tenders
  • Product packaging
  • Digital Product Passports

This avoids contradictions that regulators and customers quickly spot.

How DigiProd Pass Clarifies the Greenwashing Fogs

DigiProd Pass helps manufacturers cut through sustainability ambiguity by turning scattered claims into structured, verifiable product‑level data. Rather than relying on unclear messaging, it enables brands to link every sustainability claim directly to documented evidence and material information, providing a clear audit trail and building trust with regulators and customers alike. 

The platform also supports version control and audit readiness, so teams can track updates and ensure all sustainability data remains current and defensible. 

By centralising product information in a single source of truth that aligns compliance, marketing, and product teams, DigiProd Pass reduces the risk of unsubstantiated claims being perceived as greenwashing and strengthens brand credibility in an increasingly transparent regulatory landscape.

DigiProd Pass helps manufacturers:

  • Structure sustainability claims as product-level data
  • Link claims directly to verifiable evidence
  • Maintain version control and audit readiness
  • Align marketing, compliance, and product teams around a single source of truth

This reduces greenwashing risk while enabling confident, credible sustainability communication.

One-Page Publish Checklist + Copy-Ready Templates

Publish Checklist

Before releasing a sustainability claim:

  • Scope clearly defined
  • Evidence linked
  • Language reviewed for absolutes and ambiguity
  • Claim mapped to DPP field
  • Review date scheduled

Copy-Ready Templates

Product Claim
“This product contains 35% post-consumer recycled aluminium, measured by weight, based on supplier declarations verified in 2024.”

Operations Claim
“Our [facility/location] reduced electricity-related emissions by 18% between 2022–2024, calculated using location-based emission factors.”

Target / Progress Claim
“We aim to reduce Scope 1 and 2 emissions by 30% by 2030, relative to a 2021 baseline. Current progress: 12% achieved.”

Claim - DPP Mapping
Claim: Recycled content percentage
DPP field: Material composition
Evidence: Supplier certificate
Last updated: YYYY-MM
Owner: Sustainability team

FAQs

Is it safer to avoid sustainability claims altogether?
No. Silence can raise as much suspicion as overstatement. The goal is accurate, well-supported communication.

Can marketing teams write sustainability claims alone?
Not safely. Claims should be co-owned by sustainability and compliance functions.

Do Digital Product Passports replace marketing claims?
No. They support and validate them by providing structured, verifiable data behind the message.

Is greenwashing always intentional?
Most cases are not. They result from poor governance, unclear data, or misaligned teams.

Sources
EU Green Claims Directive
Ecodesign for Sustainable Products Regulation(ESPR)

Stopping greenwashing: how the EU regulates green claims

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