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Greenwashing in the USA: How a Company Can Use Environmental Claims

How to verify claims about ecology, recycling, and climate neutrality, and prepare evidence before publishing an advertisement.

In Brief
  • FTC expects environmental claims to be truthful and supported by appropriate evidence.
  • Green Guides explain the FTC's approach to marketing claims; they are not a standalone set of automatic prohibitions for every claim.
  • A claim about packaging should not suggest a confirmed benefit for the entire product.
  • State law and specific circumstances of the advertisement may impose additional requirements.

How to verify claims about ecology, recycling, and climate neutrality, and prepare evidence before publishing an advertisement.

Status verified: November 2, 2026. We are not a law firm. This text is for informational and educational purposes only and does not constitute individual legal advice. Before making decisions, check the regulations applicable to your location and type of business, and consult with a lawyer or other appropriate specialist.

What Consumers Understand from Advertising

An environmental message is not just a sentence on a label. The entire advertisement can matter: the product name, graphics, placement of clarifications, and the impression created in the audience. The company should be able to justify both explicit claims and reasonable interpretations derived from the whole.

The FTC advises caution with general and vague promises of environmental benefits. A claim suggesting that the entire product is environmentally friendly may require broader justification than information about one part of the packaging. The explanation should be clear and placed in a context that allows understanding of what it pertains to.

Evidence Worth Collecting

Start with manufacturer documents, material specifications, research results, and methodologies. Check if they pertain to the current product, the appropriate batch, and the full scope of the claim. If the supplier or composition has changed, old documents may not support the new advertisement.

The FTC points to the need for reliable scientific evidence appropriate to the claims. Not every advertisement requires identical research, but the evidence should correspond to what the company actually promises. Merely citing a supplier or the popularity of a claim is not sufficient as an analysis.

Recycling, Certifications, and Offsets

When providing information about recycled material, distinguish the product from the packaging and indicate what the percentage refers to. A claim about recyclability should consider the actual availability of relevant systems for consumers, according to FTC guidelines. Do not assume that a graphic symbol alone explains the full scope.

A certification should allow understanding of what has been verified and by whom. If there is a significant relationship between the company and the organization granting the mark, it may need to be disclosed. For claims based on emission offsets, check the evidence and avoid suggesting that the product's emissions did not occur if the message is based solely on a separate offset project.

Example: Recycled Packaging

A company wants to state on the box that its product is "green" because part of the cardboard comes from recycling. First, it should determine the percentage, scope, and currency of the documents. Specific information about the cardboard may be clearer than a general promise about the entire product, but its final wording must also correspond to the facts.

Document the person responsible for each claim, the source of the data, and the date of the next review. This also applies to descriptions copied from manufacturer materials and advertisements published by partners.

Reviewing Claims Before Ordering Packaging

In the first column, write the exact claim and the publication location. In the second, explain what the customer might understand from it: does the claim pertain to the product, packaging, transportation, or the entire company's operations? In the third, indicate the document, author, date, and limitations of the evidence.

Next, check if the images, color scheme, certification mark, and footnote do not alter the overall meaning. Information hidden in a distant document may not correct a misleading impression created by the main message. Pay attention to advertisements on social media, where product descriptions can be abbreviated.

Provide the list to those involved in purchasing and marketing. Before changing suppliers or materials, check if the existing evidence still applies. If the company cannot justify the claims, it should change the message or suspend its use until clarification.

Frequently Asked Questions

Are Green Guides the same as Polish law?

No. They are FTC guidelines regarding the application of U.S. law to environmental claims. EU and Polish regulations need to be analyzed separately.

Does a certification automatically validate every advertisement?

No. The scope of certification, the way it is presented, and whether the message does not suggest more than what has been verified are important.

Related Guides

Sources

DocumentWhat it Contains
FTC: Summary of Green GuidesGeneral claims, certifications, and offsets.
FTC: Environmental MarketingEvidence for environmental claims.

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