Eu Greenwashing Analysis

EU Greenwashing Analysis

Run this procedure whenever a user submits a product description, marketing

text, or catalog entry for review against EU rules on environmental claims

(Directive 2024/825 amending 2005/29/EC, and the proposed Green Claims

Directive COM/2023/166).

The output is always a structured findings report: one block per flagged

claim plus a summary. Do not editorialize outside that structure.

Step 1 — Extract all environmental claims

Read the full text and list every statement that references environmental

benefit, sustainability, ecological impact, or climate performance. Examples

include: "eco-friendly", "carbon neutral", "100% natural", "sustainable",

"green", "biodegradable", "zero emissions", "climate positive", "recycled",

"plastic-free", "low carbon", "environmentally safe".

If no such claims exist → output: "No environmental claims detected — Out of Scope." and stop.

Step 2 — Assess each claim against EU greenwashing criteria

For each extracted claim, check ALL of the following:

• Vagueness / Generic claim — Is the claim broad or unsubstantiated

(e.g., "eco", "green", "sustainable") with no measurable indicator,

certification, or evidence cited? → High risk flag.

• Incomplete life-cycle scope — Does the claim highlight one phase of

the product life cycle (e.g., recyclable packaging) while ignoring other

high-impact phases (manufacturing, transport, end-of-life)? → Medium to

High risk flag.

• Unverifiable / No third-party certification — Is there no independent

verification, recognized EU certification, or scientific reference to

support the claim? → Medium to High risk flag.

• Misleading comparison — Does the claim compare the product favorably

against an irrelevant benchmark, obsolete product, or omit material

information that would change the consumer's perception? → High risk flag.

• Carbon offset reliance — Does the claim (e.g., "carbon neutral", "net

zero") rely primarily on carbon offsetting schemes rather than actual

emission reductions? If offsets are not independently verified under

EU-recognized standards → Medium to High risk flag.

• Unsupported label or logo — Does the product display an environmental

label, badge, or logo that is not officially recognized in the EU, or

whose criteria have not been verified? → High risk flag.

• Forward-looking claim presented as current — Is a future commitment

(e.g., "will be carbon neutral by 2030") presented in a way that implies

a current state? → Medium risk flag.

Step 3 — Assign a risk level per claim

• 🔴 High — Claim is clearly unsubstantiated, misleading, or likely

non-compliant with EU Directive 2024/825 or the Green Claims Directive.

Immediate corrective action required.

• 🟡 Medium — Claim is partially substantiated but lacks full

verification, life-cycle scope, or specificity. Corrective action

recommended before publication.

• 🟢 Low — Claim is specific and plausible but should be reviewed for

formal certification before final catalog inclusion.

Step 4 — Fill the standard findings template

For EACH flagged claim, output one block in this exact format:

Product Claim: [exact quote of the claim as it appears in the text]

Risk Level: 🔴 High / 🟡 Medium / 🟢 Low

Regulation Reference: [e.g., "EU Directive 2024/825, Art. 3 — Prohibition of misleading environmental claims" or "Green Claims Directive COM/2023/166, Art. 5 — Substantiation requirements"]

Issue: [1–2 sentences explaining what makes this claim problematic under EU regulation]

Recommended Correction: [suggested compliant rewrite or specific action the team should take, e.g., "Replace with a specific, verified figure: 'Made with 40% recycled ocean plastic, certified by [recognized body]'"]

Step 5 — Summary assessment

After all per-claim blocks, output a summary in this format:

Greenwashing Findings Summary

• Total environmental claims reviewed: [N]
• 🔴 High risk: [N]
• 🟡 Medium risk: [N]
• 🟢 Low risk: [N]
• ✅ Compliant (no action needed): [N]
• Overall compliance posture: Compliant / Needs Review / Non-Compliant
• Top priority action: [single most urgent corrective step]