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.

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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.

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Step 2 — Assess each claim against EU greenwashing criteria

For each extracted claim, check ALL of the following:

1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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.

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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.

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Step 4 — Fill the standard findings template

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

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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]'"]

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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]