Green Claims
Regulatory requirements for substantiating environmental and sustainability claims made about products and services, aimed at preventing greenwashing and ensuring consumer transparency.
Foresight tracks Green Claims developments and surfaces the alerts most likely to matter before they turn into missed deadlines, recalls, or escalation work.
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Last updated
10 May 2026, 18:43
Latest Green Claims alerts
The most recent regulatory and guidance signals tracked by Foresight
Germany: DUH Files Greenwashing Lawsuit Against Bayer Over Net-Zero 2050 Climate Claims
Deutsche Umwelthilfe has awarded its 2026 Goldener Geier for the most egregious greenwashing to Bayer and filed a lawsuit at the Cologne Regional Court over the company’s long-term net-zero-by-2050 climate claims. This signals mounting legal and reputational risk for corporates whose climate neutrality pledges rely heavily on offsets and lack detailed, independently verifiable decarbonisation pathways beyond 2030.
GermanyEU EESC Adopts Opinion on 2030 Consumer Agenda and Action Plan for Consumers
In April 2026 the European Economic and Social Committee adopted a formal opinion on the EU's 2030 Consumer Agenda, signalling priorities for product safety, digital fairness and sustainable consumption across the single market. While non-binding, the opinion points to likely future reforms in consumer law, enforcement and green-claims rules that manufacturers, retailers and online platforms selling into the EU should monitor and factor into medium-term strategy.
European UnionAmsterdam Municipal Council Bans Public Advertising of Fossil Fuels and Meat
In May 2026, Amsterdam’s municipal council moved to ban public advertising of high-emission products such as fossil fuels, meat, air travel, cruises and cars across the city’s public spaces. This raises climate and ESG expectations for energy, transport and meat companies active in Amsterdam, signalling growing use of local advertising restrictions to curb demand for high-carbon products.
NetherlandsUS N.D. California Partially Denies Motion to Dismiss Greenwashing Claims in Merrell v. Florida Crystals
In April 2026, the US District Court for the Northern District of California largely allowed a consumer class action over Florida Crystals’ “sustainable” sugar marketing to proceed, holding that broad environmental benefit claims about farming practices could plausibly mislead reasonable consumers. This keeps greenwashing litigation pressure high on food and agriculture brands using eco‑claims, highlighting the need to align product labelling and sustainability messaging with actual farming and environmental practices as cases advance into discovery and potential injunctive relief.
United StatesLuxembourg Draft Law Transposing Directive (EU) 2024/825 on Empowering Consumers for the Green Transition
Luxembourg is advancing Draft Law PL 8648 to transpose Directive (EU) 2024/825 on empowering consumers for the green transition into its Consumer Code, with the Chamber of Employees issuing a supportive opinion and the new rules planned to apply from 27 September 2026. The law will tighten enforcement against greenwashing and early obsolescence and require new pre‑contractual information on guarantees, software updates and repairability across most consumer products, so businesses should plan changes to marketing, labelling and product design ahead of the 2026 start date.
LuxembourgCalifornia AB 1812 Would Ban 'Compostable' Labels on Plastic Products From 2027
California lawmakers are advancing AB 1812, a bill that from 1 January 2027 would ban “compostable” or “home compostable” labels on any product containing plastic while tightening certification rules for compostable claims. As of 29 April 2026, the bill has passed Assembly Natural Resources and is on the Assembly Appropriations Committee suspense file, so it remains active but may still change before any final vote. This would force brands selling into California to rethink compostable packaging strategies, likely pivoting away from plastic-based materials toward fibre-only or other non-plastic options aligned with local composting infrastructure and organics markets.
United StatesUS Class Actions Challenge Keurig "Recyclable" K-Cup Labelling
Consumers in California and New York have filed new class actions alleging Keurig’s “recyclable” K-Cup labelling is deceptive because most recyclers do not accept the pods, building on a 2023 settlement and a 2024 SEC penalty over related recyclability claims. This combination of private litigation and securities enforcement raises the bar for how brands substantiate recyclable and other environmental claims on packaging and in ESG disclosures, pushing closer alignment with real-world recycling infrastructure and guidance.
United StatesUK NCP Accepts Complaint on Virgin Atlantic Environmental Claims for Further Examination
In May 2026 the UK National Contact Point for the OECD Guidelines accepted elements of a complaint alleging that Virgin Atlantic’s environmental and net-zero marketing claims are misleading, and opened a mediation and further-examination process under the Guidelines’ environment and consumer-interest chapters. This signals intensifying scrutiny of corporate green claims in aviation and other sectors, underscoring the need for robust, verifiable and well-contextualised climate communications that align with both OECD expectations and domestic consumer-protection regimes.
United KingdomNetherlands Supreme Court Advocate General Issues Opinion on Green Marketing of Old HP Printer Cartridges
In April 2026 the Advocate General at the Dutch Supreme Court issued a non-binding opinion in HP v Digital Revolution on selling very old HP printer cartridges without boxes as “milieuproduct” at new prices. If followed by the Court, this will confine trademark-based challenges to such resale but confirm that resellers must transparently disclose product age when using environmental or “return” marketing claims in the Dutch market.
NetherlandsCalifornia Assembly Appropriations Committee Sets First Hearing for AB 2253 and Places It on Suspense File
California’s AB-2253, a bill to tighten environmental marketing rules for products under the state solid waste law, has been set for its first hearing and placed on the Assembly Appropriations Committee suspense file as of 22 April 2026. This procedural move confirms the bill’s fiscal implications but keeps it active, so companies making environmental or “green” claims in California should watch for further committee action that could crystallise new documentation and substantiation duties.
United StatesCalifornia SB 343 and SB 54: Upcoming Recyclability Labelling and Packaging EPR Requirements
California’s SB 343 and SB 54 will sharply tighten recyclability labelling and introduce a mandatory packaging extended producer responsibility regime from October 2026 and January 2027, imposing strict criteria for when products can be marketed as recyclable and when producers may sell covered packaging in the state. These shifts will force brands and packaging suppliers to redesign materials, reassess PFAS use, overhaul “recyclable” claims, and join funded producer responsibility organisations, increasing compliance costs and litigation risk as California diverges from federal and other state rules.
United StatesEuropean Parliament Written Question on Blue Flag Programme Under Directive (EU) 2024/825
An MEP has submitted a priority written question asking how Article 7 of Directive (EU) 2024/825 on generic environmental claims applies to established eco-label and environmental recognition programmes such as the Blue Flag scheme. This signals potential scrutiny of how new EU green-claims rules may affect the use of third-party environmental recognition labels in marketing and governance, although obligations remain unchanged until the Commission issues an interpretation.
European UnionNetherlands House Adopts Implementing Act for Directive (EU) 2024/825 on Consumer Green Claims (36873)
In April 2026 the Dutch House of Representatives adopted an implementing act amending the Civil Code to transpose EU Directive 2024/825 on empowering consumers for the green transition. Once fully enacted and in force, this will tighten Dutch rules on sustainability-related consumer information and unfair commercial practices, raising compliance expectations for green claims across consumer markets.
NetherlandsEuropean UnionUS: Proposed PACK Act and State-Level PFAS and Polystyrene Packaging Restrictions
US packaging regulation is tightening as Congress considers the PACK Act to set national standards for green packaging claims while New York and Virginia implement bans on PFAS-containing food packaging and expanded polystyrene foam that fully bite by 2026. Companies selling into the US market need to accelerate shifts to PFAS-free, foam-free packaging and rigorously substantiated recyclability and compostability claims to avoid non-compliance, greenwashing risk, and disruption to packaging supply chains.
United StatesEU Council Publishes Statement of Reasons for Position (EU) No 2/2026 on Accounting of Greenhouse Gas Emissions of Transport Services
The EU Council has published in the Official Journal its statement of reasons for Position (EU) No 2/2026 at first reading on the Regulation governing greenhouse gas emissions accounting of transport services, formalising the political justification for its agreed text. This adds interpretative context but no new obligations, helping transport operators and large buyers anticipate how the forthcoming EU-wide GHG accounting standard for transport services is likely to be applied once the Regulation is finally adopted and implemented.
European UnionUS Law Firm Highlights PFAS, ESG, and CPSC Reporting Risks for Consumer Products Companies
An April 2026 K&L Gates analysis warns that expanding state consumer-protection laws, PFAS-related contamination claims, ESG litigation, and CPSC Section 15 enforcement are creating significant operational and legal risk for US consumer-products companies. Companies should respond by building integrated 50-state regulatory-intelligence and claims-substantiation systems that map PFAS and microplastics in supply chains, tighten “Made in USA” and sustainability claims, and ensure early escalation of safety information to comply with CPSC reporting obligations.
United StatesEU Ombudsman Opens Case on ESMA’s Failure to Reply on Sustainability Claims
In April 2026 the European Ombudsman opened an inquiry into ESMA’s failure to reply to a stakeholder letter on sustainability claims, integrity, and predictability in its work. This does not yet change compliance duties but signals heightened scrutiny of how EU financial regulators handle ESG-related communications, which could shape future expectations on green and sustainability claims oversight.
European UnionHawaii SR128 Requests Department Of Health Study On Recyclable, Biodegradable And Compostable Labelling
In March 2026 the Hawaii Senate introduced Resolution SR128 directing the state Department of Health to study whether “recyclable”, “biodegradable” and “compostable” labels on products sold in the state accurately reflect real recycling and composting options and to recommend clearer standards. The requested 2027 report, including any draft legislation, could drive stricter green marketing rules, new labelling requirements, and higher compliance risk for packaging and consumer products in the Hawaii market.
United StatesHawaii Concurrent Resolution Requests DOH Study on Recyclable and Compostable Labelling
In April 2026, the Hawaii Legislature advanced House Concurrent Resolution 205, which would direct the Department of Health to study whether “recyclable,” “biodegradable,” and “compostable” product labels used in the state are accurate and non-deceptive. The study would compare green marketing claims with Hawaii’s actual recycling and composting capabilities and deliver recommendations and potential legislation by the 2027 session, signalling possible tighter packaging and environmental labelling rules for consumer products sold in the state.
United StatesItaly AGCM Secures Removal of 24Bottles Green Claims via Moral Suasion
In April 2026 Italy’s competition authority used moral suasion to make 24Bottles remove “zero impact”, “climate neutrality”, and similar offset-based green claims from its online marketing. This signals growing enforcement pressure on unsubstantiated climate-related claims and highlights the legal and reputational risks of relying solely on carbon offset projects in consumer communications.
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