With regulators cracking down harder than ever on greenwashing (see the CMA’s latest guidance and the DMCC Act), and consumers empowered by social media to call out misleading claims, 2024 and 2025 have seen a wave of greenwashing lawsuits across industries that not only threaten company reputations, but also carry the risk of fines of up to 10% of annual revenues. These cases underscore the importance for brands and retailers to communicate their sustainability claims and initiatives with honesty, clarity, and impact.
Let’s explore the most recent high-profile examples of greenwashing, breaking down what happened and the lessons businesses can take away to protect themselves from costly mistakes.
A class-action lawsuit was filed against Procter & Gamble, accusing the company of greenwashing its Charmin toilet paper. Although P&G promoted its commitment to responsible forestry, the lawsuit claimed that the brand sourced wood pulp from Canada’s boreal forest, a critical region for biodiversity and carbon storage. Critics argued that this contradicted the company’s sustainability promises and misled consumers about the environmental impact of its products.
The class-action lawsuit has intensified scrutiny on P&G’s environmental practices, exposing gaps between its marketing and sourcing realities. The company faces reputational damage and increased pressure from environmental groups and investors. In response, P&G has pledged to disclose more details about its wood-pulp audits and supply chain oversight by mid-2025. Additionally, it has committed $20 million over five years to develop sustainable alternatives to wood pulp. The case underscores the risks companies face when sustainability claims are not fully backed by verifiable actions.
→ Companies must ensure that sustainability claims align with their sourcing practices and are supported by verifiable information
→ Any gaps between what is marketed and what occurs in the supply chain can quickly become liabilities
The UK’s Competition and Markets Authority (CMA) launched an (ongoing) investigation into ASOS, Boohoo, and Asda in 2022 after finding that their sustainability claims—particularly around “eco-friendly” and “sustainable” clothing lines—were potentially misleading. The UK regulator found that companies used broad, vague phrases that gave the impression that products had a low environmental impact, but these claims were not sufficiently backed by data. Moving forward, it will be necessary for these retailers to file regular reports to the UK regulator.
The investigation has led to mandatory reforms in how ASOS, Boohoo, and Asda present sustainability claims, forcing them to implement stricter marketing controls and transparency measures. These changes are under ongoing regulatory supervision, placing their future advertising practices under greater scrutiny while exposing them to reputational risks if they fail to comply.
→ Brands must avoid using catch-all phrases like “green” or “sustainable” without context
→ Specific, evidence-backed details about materials, production processes, and certifications are necessary to ensure that claims are both accurate and trustworthy. Without them, companies risk misleading consumers and attracting regulatory scrutiny
KLM’s Fly Responsibly campaign positioned the airline as a leader in sustainable aviation which, according to environmental groups, paints a “too rosy” picture about its efforts to reduce emissions. Environmental groups filed a legal challenge, arguing that the campaign overstated the impact of carbon offsets and misled consumers into believing that buying offsets would directly lower the carbon footprint of their flight. The case highlights the growing debate around the effectiveness of carbon offset programs.
The legal challenge against KLM’s Fly Responsibly campaign has led to increased scrutiny of carbon offset claims across the aviation industry. While the case is ongoing, it has already triggered reputational damage, with environmental groups and public opinion questioning KLM’s sustainability narrative. The lawsuit has also pressured the airline to revisit its marketing practices and provide clearer disclosures about the limitations of carbon offsets. Industry-wide, it signals a warning to companies relying heavily on offsets to avoid regulatory backlash and erosion of consumer trust.
→ Carbon offset claims must be accurate and communicated with full transparency
→ Companies should clearly explain the limitations of offsets and focus on meaningful emissions reductions alongside offset strategies. Overreliance on offsets without proper context can damage credibility and invite public criticism
→ Companies should disclose the business’s carbon footprint, the percentage offset, and the specific offset projects used (e.g., removal or avoidance) to ensure transparency and build trust
Shein’s fast fashion model has long faced criticism, but its evoluSHEIN collection, marketed as a sustainable product line, triggered an investigation by Italy’s antitrust authority. The investigation centers on allegations that Shein misled consumers about the percentage of “green” fibers used in its evoluSHEIN garments and failed to disclose that many items were not recyclable. Critics argue that this collection serves as a distraction from Shein’s broader environmental impact, as the company remains one of the largest contributors to textile waste and rising emissions. Additionally, regulators highlighted discrepancies between Shein’s claims of reducing carbon emissions and the increasing greenhouse gas emissions reported in its sustainability reports for 2022 and 2023, pointing to a lack of transparency and measurable evidence.
The investigation by Italy’s antitrust authority is still ongoing, and Shein is under scrutiny for potentially misleading environmental claims. While no specific fines have yet been issued, potential penalties could arise if the company is found in violation of consumer protection laws. Shein has pledged to cooperate with regulators and address concerns over its sustainability practices, with the outcome likely to influence its future marketing strategies and supply chain transparency.
→ Fast fashion brands face heightened scrutiny and must ensure that sustainability claims are backed by hard data
→ Companies should provide measurable goals, report progress transparently, and avoid making vague or generalised statements about sustainability
Coca-Cola was accused of quietly dropping its 25% reusable packaging goal after environmental groups noticed that the commitment had been removed from the company’s website. The groups argued that this change demonstrated a lack of follow-through on public commitments and undermined the credibility of the company’s broader sustainability efforts. The backlash drew widespread attention, reigniting concerns over greenwashing in the beverage industry.
Coca-Cola has not officially commented or clarified the reasons for removing its 25% reusable packaging goal. There have been no verified updates on specific revised sustainability targets tied directly to this controversy, leaving its long-term environmental credibility under increased scrutiny.
→ Public sustainability commitments should be treated as long-term obligations, not for sole use as marketing slogans. Companies should exercise caution in the execution of sustainability marketing campaigns without sufficient evidence to substantiate their claims
→ If adjustments to targets are necessary, brands must be transparent and explain the reasons behind the changes to maintain trust
Qantas promoted its Fly Carbon Neutral program as a way for passengers to offset the environmental impact of their flights, but climate activists challenged these claims, accusing the airline of overstating the effectiveness of its offsets. The complaint highlighted concerns that consumers were being misled into thinking they were making a significant environmental contribution, even though the impact of carbon offsets can vary widely depending on the project.
In response, Qantas acknowledged the challenges in decarbonising aviation and emphasised its commitment to high-integrity carbon offsets and investments in sustainable aviation fuels. The ACCC has yet to announce any findings or actions regarding this complaint.
→ Carbon-neutral marketing claims based on carbon offsets are always misleading as they give the false impression that a product has a lower carbon footprint than another
→ Companies must provide clear and transparent information on how offsets are calculated, the projects involved, and the limits of their effectiveness. Without this level of transparency, brands risk losing consumer trust
Target’s Target Clean label, designed to help consumers identify products free from harmful chemicals, was challenged in a recent lawsuit. Plaintiffs claimed that some products carrying the label contained ingredients that contradicted the clean label’s promise (and in fact were on a banned ingredients list), effectively misleading consumers into believing that the products were more sustainable or “clean” than they actually were.
In September 2024, a federal court in Minnesota denied Target's motion to dismiss a class-action lawsuit concerning its "Target Clean" label. The court acknowledged that consumers might reasonably assume Target had independently verified the safety of these products, given the retailer's reputation and the explicit "clean" labeling. This decision allows the lawsuit to proceed, potentially leading to increased scrutiny of Target's marketing practices, potential fines and broader implications for corporate sustainability claims.
→ Retailers must establish clear criteria to describe eco-labels and ensure that they are rigorously followed. Broad labels like “clean” or “eco-friendly” can lead to legal challenges if they lack consistent standards or fail to meet consumer expectations
→ Third-party verification is often a valuable safeguard. Retailers can use the open access Provenance Framework as a starting point
Lululemon faced criticism from environmental groups over its Be Planet campaign, which promoted the company’s sustainability initiatives. Activists argued that the campaign exaggerated the brand’s positive impact and overlooked key environmental issues, including the carbon footprint of its production processes. Critics also highlighted that modern consumers are increasingly savvy and unlikely to be swayed by green buzzwords, especially when brands fail to demonstrate significant, measurable progress toward meaningful sustainability.
Lululemon has responded to the greenwashing lawsuit, stating that Be Planet is not a marketing campaign but a core part of its impact strategy. The company emphasised that the initiative outlines its climate targets, including a 2030 commitment and a 2050 Net Zero goal, both validated by the Science Based Targets Initiative (SBTi). Confident in its environmental claims, Lululemon highlighted a 60% emissions reduction in owned facilities while acknowledging most emissions stem from its supply chain. The company remains committed to improving supply chain sustainability and advancing its environmental goals.
→ Superficial campaigns/communications on sustainability initiatives that lack depth or measurable progress can easily backfire in reputationally damaging ways
→ Authentic sustainability marketing must be backed by operational improvements and evidence-based outcomes, not just aspirational messaging
In today’s rapidly evolving landscape, sustainability is not just a marketing tool—it’s a business imperative. As companies face mounting risks from regulatory fines, consumer-driven backlash on social media, and within the context of accelerating climate disasters, integrating sustainability into core operations is essential for long-term success. Consumers, particularly Gen Z and millennials, are driving the demand for transparency, and viral exposure of brand missteps can damage reputations in an instant.
To avoid these risks, companies must take proactive steps:
By embedding sustainability into their business models and ensuring truthful communication, companies can not only avoid fines but also outperform competitors in a market where sustainability is increasingly a key driver of customer value.
Alicia is a communications and growth consultant with a background in product and marketing at startups. She is passionate about sustainability and tech for good.
Provenance powers sustainability claims you can trust. The global leader in sustainability marketing technology, Provenance helps brands and retailers share credible, compelling and fact-checked social and environmental impact information at the point of sale. Provenance’s technology is already increasing conversion rates, brand value and market share for customers including Cult Beauty, Douglas, GANNI, Napolina, Arla and Unilever
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