Avoiding Greenwashing: How Companies Can Honestly Communicate Their Contributions to Climate Protection

At the end of January 2026, the Federal Council approved the Anti-Greenwashing Act. This means that, effective September 27, 2026, companies may only use terms such as “climate-neutral,” “environmentally friendly,” or “green” if they can back them up with concrete, publicly available evidence. The law transposes the EU EmpCo Directive (EU) 2024/825 into German law and significantly tightens the provisions of the German Unfair Competition Act (UWG).

The courts, however, aren’t waiting until September. In 2025 alone, Deutsche Umwelthilfe and the Federal Association of Consumer Organizations secured a series of rulings against major companies: The Frankfurt Regional Court prohibited Apple from advertising its smartwatches as “CO₂-neutral.” The Cologne Regional Court halted Lufthansa’s advertising for climate-neutral flights available for an additional fee. The Berlin Regional Court prohibited Google from presenting emissions savings on Google Flights as facts rather than estimates. And Obi also lost its case before the Cologne Regional Court because the home improvement store had advertised a wall paint as “climate-neutral” without explaining how this neutrality was achieved.

These cases show that avoiding greenwashing is not merely a moral issue for companies, but a legal and economic necessity. This article highlights the most common pitfalls, their costs, and what credible climate communication looks like instead.

When Climate Communication Becomes Greenwashing—and What It Costs

The line between genuine sustainability communication and greenwashing isn’t always clear. Many companies fall into this trap without meaning to. They oversimplify because complex climate issues are difficult to boil down to a slogan. Or they use phrasing that was standard in the industry just a few years ago.

It is crucial to distinguish between different types of climate claims. In our first post in this series, we broke down the different types of climate claims and what sets them apart. In short: A neutrality claim (“We are climate-neutral”) suggests that there are no negative climate impacts. A reduction claim describes verifiable progress in reducing a company’s own emissions. And a contribution claim explains the specific contribution a company is making, without claiming that its own emissions have been offset. 

The perspective of our partner, eva, also demonstrates that credible climate communication depends not only on the wording of a claim, but also on the quality of the underlying projects. In a follow-up article, eva explains why transparency, standardized MRV processes, and independent verification are crucial for robustly demonstrating climate impact and avoiding greenwashing.

Click here to read the article

‍The most common greenwashing patterns:

• Marketing Offsets as Climate Neutrality: A company purchases CO₂ credits and declares itself “climate neutral” without significantly reducing its own emissions. In the case of the Apple Watch, for example, the “CO₂ neutrality” was based on a eucalyptus reforestation project in Paraguay, where the lease agreements for 75 percent of the land expire in 2029. Starting in September 2026, such offset-based neutrality claims will be prohibited.
• Scope Picking: Companies that report only Scope 1 and Scope 2 emissions but omit Scope 3 (supply chain) emissions paint a distorted picture. For most companies, Scope 3 emissions account for the largest share.
• Cherry-picking in projects: A photogenic reforestation project takes center stage, but there is no overarching climate strategy behind it. Projects are credible only if they are embedded in a emissions reduction pathway.
• Vague terms lacking substance: “environmentally friendly,” “green,” “sustainable”—without concrete evidence. Starting in September 2026, the Unfair Competition Act (UWG) will require evidence to be provided directly on the medium itself.

The consequences are affecting companies on multiple levels simultaneously. DWS is the most dramatic example: In April 2025, the Frankfurt public prosecutor’s office imposed a fine of 25 million euros —the highest greenwashing penalty in German history. Combined with the $25 million SEC fine from 2023, the financial damage totals around 50 million. Added to this were Greenpeace protests in 30 cities, the CEO’s resignation, and damage to the brand.

But even companies that “only” lose an injunction lawsuit pay a high price. According to its own figures, the DUH has issued warnings to over 100 companies and filed lawsuits since 2022, with a 100% success rate so far. The amendment to the Unfair Competition Act, which includes anti-greenwashing provisions, provides for fines of up to 4 percent of annual revenue. Observers expect a wave of warnings starting in the fall of 2026.

Greenhushing: Why Silence Isn't the Answer Either

Tighter regulations have led to a paradoxical reaction. Instead of improving their communication, some companies prefer to remain completely silent. Experts have coined the term “greenhushing” to describe this phenomenon: the deliberate reluctance to communicate about one’s own climate actions.

The numbers speak for themselves: According to Netfederation’s CR Benchmark 2025, standalone corporate responsibility blogs have plummeted by 30 percent since 2021. Only 10 percent of the companies surveyed still maintain one. A mere 30 percent transparently publish their biodiversity metrics online, and only one in five companies uses digital features such as interactive dashboards to showcase progress. A study by Harvard University also shows that, of the 75 global companies surveyed, only 13 percent actually scaled back their climate strategies after the 2024 U.S. election, yet communication about these strategies is becoming less prominent.

This is counterproductive to climate protection as a whole. If you don’t communicate your progress, you won’t inspire anyone, and genuine commitment will go unnoticed. In the long run, silence signals a lack of substance, not caution. The solution lies not in communicating less, but in communicating better.

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From Climate Statement to Sustainability Strategy

Individual climate claims can be challenged relatively easily. What courts and regulators cannot challenge is a well-thought-out sustainability strategy that underpins your communications with substance. The difference: Instead of defending a slogan, you have evidence.

Contribution Claims Instead of Neutrality Claims

Instead of saying, “We are climate-neutral,” say: “We are investing in the conversion of climate-vulnerable coniferous forests into resilient mixed forests, thereby making a measurable contribution to the restoration of climate-resilient forests in Germany.” A contribution claim describes the specific contribution to climate protection without claiming that it offsets the company’s own emissions. This is not only more honest but also keeps you on the safe side from a regulatory standpoint.

Transparency Regarding the Reduction Path

Show where you stand and where you want to go. Publish your carbon footprint, including Scope 3 emissions, to the extent possible. Set reduction targets, ideally validated by the Science Based Targets Initiative (SBTi). And report regularly on your progress, even if it’s not perfect yet. Consistent reporting over the years is more convincing than a one-time statement.

Projects with measurable impact

At Pina Earth, we develop climate protection projects in Central European forests with a duration of at least 30 years. In Germany alone, approximately 3 million hectares of forest must be adapted to climate change—equivalent to one-quarter of the total forest area. Our projects are certified by TÜV in accordance with ISO 14064-2 and primarily generate carbon removal certificates—that is, CO₂ that has actually been removed from the atmosphere. Companies and their customers can track the progress of each individual project at any time via our interactive forest dashboard. After all, credible climate communication depends not only on the right claims, but also on the quality of the projects behind them. Our partner eva’s blog post also highlights just how important transparency, standardized MRV processes, and independent verification are in this context. [Link to the eva blog post]

Who is our partner, eva, and what do they do?‍

Eva was founded to promote environmental and climate protection and develops internationally recognized standards for the payment of ecosystem services. With the Forest Climate Standard, Eva lays the groundwork for channeling private capital—through CO₂ credits—into the restoration, transformation, and management of climate-resilient forests in Germany and Europe.

“Credible climate communication requires more than just good intentions. It is crucial that the impact behind it be transparent, verifiable, and independently auditable.”
— Rüdiger Meyer, Managing Director of eva

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Here is a summary of the most important steps you can take now to ensure your climate communication is effective:

• Check the website, packaging, and marketing materials for generic environmental terms such as “climate-neutral,” “environmentally friendly,” or “green.”
• Replace claims of neutrality with specific claims of contribution that demonstrate what you are actually doing to help combat climate change.
• Make sure that all environmental claims are explained directly within the medium itself, rather than through external links or QR codes.
• Document your emissions reduction strategy transparently, including Scope 3 emissions and sustainability goals.

In Part 1 of our blog post series on "Clarity in Claims," you'll find more information about the different types of claims.

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Frequently asked questions

Climate-Neutral Advertising: What Will Still Be Allowed Starting in 2026?

Starting September 27, 2026, the term “climate-neutral” will be prohibited in media without concrete evidence. Courts in Frankfurt, Cologne, and Berlin have already banned a number of such claims: The Frankfurt Regional Court prohibited Apple from using “CO₂-neutral” advertising for the Apple Watch, the Cologne Regional Court halted Lufthansa’s advertising for climate-neutral flights, and the Berlin Regional Court banned Google from displaying misleading emissions information on Google Flights. This is based on the Federal Court of Justice’s landmark ruling from 2024 (Case No. I ZR 98/23), which applies the same strict standards to environmental advertising as it does to health-related advertising. “Contribution claims”—which specifically describe how a company contributes to climate protection without claiming that its own emissions are offset—remain permitted.

What is the difference between greenwashing and greenhushing?

Greenwashing occurs when a company portrays itself as more environmentally friendly than it actually is. Greenhushing is the opposite: a company conceals its sustainability efforts, often out of fear of being accused of greenwashing. Both are problematic, as neither exaggeration nor concealment contributes to a credible sustainability transformation.

Greenwashing Penalties in Germany: What Consequences Do Companies Face?

The consequences range from warning letters and injunctions to fines and even criminal investigations. DWS paid a fine of 25 million euros in Germany alone, plus an additional 25 million U.S. dollars to the U.S. Securities and Exchange Commission (SEC). The Anti-Greenwashing Act provides for fines of up to 4 percent of annual revenue starting in September 2026. Added to this are damages that are difficult to quantify: loss of reputation, a loss of investor confidence, and the resignation of senior executives.

What are some recent examples of greenwashing in Germany?

2025 was a record year for greenwashing rulings: The Frankfurt Regional Court prohibited Apple from advertising the Apple Watch as “CO₂-neutral,” the Cologne Regional Court halted Lufthansa’s advertising for climate-neutral flights, and the Berlin Regional Court banned Google from displaying misleading emissions information on Google Flights. In April 2025, the Frankfurt Public Prosecutor’s Office imposed the highest greenwashing fine in German history on DWS. The landmark ruling by the Federal Court of Justice (BGH) against a fruit gum manufacturer in 2024 remains the most important precedent.

Anti-Greenwashing Act of 2026: What Changes Do Companies Need to Make Now?

The Anti-Greenwashing Act will take effect on September 27, 2026, and will tighten the Unfair Competition Act (UWG) in several respects. It will then be prohibited to use general environmental terms without supporting evidence, make compensation-based neutrality claims, and make statements about future environmental performance without a verifiable implementation plan. Until then, companies should review all environmental statements on their websites, packaging, and marketing materials; replace neutrality claims with contribution claims; and ensure that supporting evidence is available directly within the medium itself, rather than only via external links or QR codes. A step-by-step overview can be found earlier in this article.

Conclusion

Avoiding greenwashing while clearly communicating about climate protection is not a contradiction. It requires a shift in thinking: away from simplistic labels and toward concrete, verifiable statements about one’s own contribution. By September 2026, marketing, legal, and compliance departments must work together to review all corporate communications. Companies that invest now in a credible climate strategy—with transparent reduction pathways and verifiable climate protection projects—will gain a real competitive advantage.

At Pina Earth, we help companies clearly document their contribution to climate protection and communicate it credibly. Talk to us about how this can work for your company

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