Global Regulatory Actions and Enforcement on Greenwashing

United States

Securities and Exchange Commission (SEC) Climate Risk Disclosure Rule

The SEC is intensifying scrutiny on ESG-related disclosures, mandating that public companies report climate-related risks and emissions data in a consistent, auditable format.

SEC Enforcement Actions

Keurig Dr. Pepper: The SEC settled an enforcement case focusing on the company's disclosures about the recyclability of its K-Cup pods, highlighting the importance of complete and accurate environmental claims. Regulatory & Compliance

WisdomTree Asset Management: Faced charges for failing to adhere to its own ESG investment criteria in certain ETFs, leading to a settlement with the SEC. Freiberger Haber LLP

State-Level Actions

States like New York are actively pursuing greenwashing cases, focusing on general statements that may mislead consumers about environmental practices. Beveridge & Diamond PC

European Union

Empowering Consumers for the Green Transition Directive (EmpCo Directive)

Adopted in 2024, this directive aims to strengthen consumer rights by requiring that environmental claims be substantiated with scientific evidence and prohibits vague or misleading terms like "sustainable" or "eco-friendly" without proper justification.

Green Claims Directive

Set to apply from September 27, 2026, this directive will ban generic environmental claims based solely on greenhouse gas emissions offsets unless they are substantiated with precise metrics and verified data. Green Claims Directive

United Kingdom

Financial Conduct Authority (FCA) Anti-Greenwashing Rule

Effective from May 31, 2024, this rule requires FCA-authorized firms to ensure that sustainability claims are clear, fair, and not misleading, with adequate substantiation. FCA Anti-Greenwashing Rule

Competition and Markets Authority (CMA) Enforcement

The CMA has been granted new enforcement powers under the Digital Markets, Competition and Consumers Act 2024, allowing it to impose fines of up to 10% of global turnover for noncompliance with greenwashing regulations. CMA Enforcement

Australia

Australian Securities and Investments Commission (ASIC) Actions

ASIC has taken significant steps against greenwashing, including imposing a penalty of AUD 12.9 million on an investment firm for misleading ESG claims. ASIC Actions

Vanguard Investments Australia

In September 2024, ASIC achieved its largest penalty to date for greenwashing in court action against Vanguard Investments Australia concerning claims about the ESG credentials of one of its funds. Kluwer Competition Law Blog

Canada

Competition Act Amendments

Canada has amended its Competition Act to directly target greenwashing, requiring that environmental claims be based on adequate testing using internationally recognized methodologies before public dissemination. Competition Act Amendments

Germany

Federal Constitutional Court Ruling

In June 2024, the court ruled that companies using terms like "climate neutral" in advertising must define what the term means, as such phrases are too vague and potentially misleading. Wikipedia

Norway

Consumer Ombudsman Guidelines

Norway's consumer ombudsman has enforced strict advertising guidelines, targeting automakers who claim their cars are "green," "clean," or "environmentally friendly," requiring substantiation for such claims. Wikipedia

South Africa

TotalEnergies Ruling

The South African Advertising Regulatory Board found that TotalEnergies' campaign with SANParks was misleading regarding their commitment to sustainable development, marking a significant precedent in greenwashing enforcement in the country.