Greenwashing Risk Register
Most greenwashing exposure does not come from one indefensible claim. It comes from four defensible ones that nobody has ever listed in the same place — made by different teams, at different times, for different audiences, and governed by four different instruments. This register builds that list, tells you which instrument owns each claim, and reports whether the set is enumerated, documented and reviewed. It does not test the claims themselves; each one has its own checker for that.
Most greenwashing risk is not one indefensible claim. It is several defensible ones nobody has listed in the same place, owned by different teams and appearing on different surfaces.
Seven questions, about a minute. This one does not test whether any claim holds — it builds the register of what you are claiming, where, and who owns the evidence, and points each claim at the instrument that governs it.
- Move the substantiation from informal to per-claim. Evidence that lives in the head of whoever ran the numbers is evidence you cannot produce on the day somebody asks for it.
- Get the claims that appear in marketing reviewed by someone outside the team that made them. Marketing surfaces are where consumer-protection regimes look first and where sustainability teams look last.
- Test each claim against the instrument that governs it. The register tells you which one that is for each; it deliberately does not repeat what those tests ask.
- Your claims appear in marketing as well as reporting, and those are governed by different regimes with different tests. We do not adjudicate the CMA Green Claims Code, the FTC Green Guides or the EU Green Claims Directive, and this register says nothing about your exposure under them.
What would change this verdict
- External review of the marketing claims closes the most exposed finding here without touching the underlying evidence.
- Moving evidence to a per-claim basis changes the governance position even if none of the claims themselves change.
The register — every claim, its governing instrument, and where to test it
| Claim | Position | Where it is tested |
|---|---|---|
| Carbon neutral | ClaimedGoverned by ISO 14068-1open | Routes to the Carbon Neutral Claim Checker |
| Renewable electricity | ClaimedGoverned by Scope 2 Guidanceopen | Routes to the Renewable Electricity Claim Checker |
| Avoided emissions | Not claimedOut of scopemet | No claim to register |
| Net zero | ClaimedGoverned by SBTi Net-Zeroopen | Routes to the SBTi Readiness Checklist |
| Surfaces | Marketing and reportingTwo regimes applyopen | Declared by you |
| Substantiation | Held informallyNot per claimopen | Declared by you |
| Review | Nobody outside the teamUnreviewedopen | Declared by you |
| Consumer law | Claims appear in marketingNot assessed hereopen | No standards page held — named, not adjudicated |
Why this verdict: More than one claim type is in use across more than one surface, and the substantiation for them is held informally rather than per claim. That is a governance finding rather than a finding about any one claim: each may well be supportable on its own instrument, and this page does not test them. What it tests is whether the set is enumerated, documented and reviewed, because a claim nobody has written down is one nobody can defend on the day it is questioned. The claims appearing in marketing carry the most exposure and have had the least scrutiny, which is the usual shape of this problem rather than an unusual one. Consumer-protection law applies to those surfaces separately and is not assessed here.
This register classifies and routes; it does not re-adjudicate. Each claim is handed to the instrument that governs it rather than re-tested here, because restating four sets of criteria on one page guarantees they drift apart the moment one of them is revised. Nothing is counted as a verdict: the head reports whether the set is enumerated, documented and reviewed, and the rows are the register. Consumer-protection law is named and not adjudicated.
The instruments behind these claims are moving independently of each other — one has already been withdrawn and replaced, another is mid-revision. A register goes stale when any one of them changes. We will email you when that happens.
This register maps which environmental claims you make and which instrument governs each. It does not test whether any individual claim holds — each row points at the checker that does — and it does not assess your exposure under advertising or consumer-protection law. It is not legal advice.
What this verdict means
Six outcomes about your governance of the claims, not about whether any of them holds. The top one belongs to the organisation most confident it is fine, because each individual team believes somebody else is holding the file.
Unsupported
Claims are in market and the substantiation is written down nowhere. This is not a finding that the claims are false — it is a finding that you could not show they are true on the day you were asked, which is the position that actually causes damage.
Unreviewed
Claims appear in marketing and nobody outside the team that made them has read them. Each may be perfectly defensible; none has been read by someone whose job is to ask whether it is.
Undocumented
The evidence exists and is not held against the claims it supports. A central folder answers “do we have support for our claims” and not “what supports this sentence” — and it is the second question that gets asked.
Documented
Enumerated, evidence per claim, reviewed internally. Materially better than most organisations manage. The remaining step is the one that cannot be done from inside.
Assured
Enumerated, documented per claim, externally assured. A governance position — not a ruling on any individual claim, which is still each instrument’s job.
No claims
None of the four types is in use. The cleanest place to be, and worth recording so that the next person to draft a brochure knows it was a decision rather than an accident.
Why the risk is in the surface, not the sentence
Every other tool in this hub asks whether one claim holds. That is the right question and it is not the one that catches organisations out.
What catches them out is arithmetic of a different kind. A company makes a carbon-neutral claim on its packaging, a renewable-electricity claim in the annual report, an avoided-emissions figure in a sales deck and a net-zero commitment in a tender response. Four claims, four surfaces, four different people who wrote them, four instruments that govern them — and no single document that lists all four.
Not “is this claim supportable?” but “what are we claiming, in total, across everything we publish?” Almost nobody can answer it from memory, and the answer is what a regulator, a customer or a journalist assembles first.
The asymmetry matters. You defend claims one at a time; they are collected all at once. Whoever is looking at you will find every claim on every surface before they assess any of them — and inconsistencies between them are more damaging than weaknesses within them, because an inconsistency looks deliberate.
The four claims, and who governs each
Each of these is a different claim under a different instrument with a different test. Treating them as one family of “green claims” is how a company ends up applying the wrong standard to the right claim.
| Claim | Governed by | Where it is tested |
|---|---|---|
| Carbon neutral | ISO 14068-1 | Carbon Neutral Claim Checker |
| Renewable electricity | GHG Protocol Scope 2 Guidance | Renewable Electricity Claim Checker |
| Avoided emissions | WBCSD avoided emissions guidance | Avoided Emissions Claim Checker |
| Net zero | SBTi Corporate Net-Zero Standard | SBTi Readiness Checklist |
The instruments are also moving independently of each other. One has already been withdrawn and replaced. Another is mid-revision. A register assembled two years ago and never revisited is describing a world that has partly stopped existing — which is a reason to date it.
Enumeration is the part everyone skips
The register offers “not sure” as an answer to every claim question, and that is not politeness. It is the single most useful answer on the page.
If you cannot say whether your organisation makes a carbon-neutral claim, somebody outside it will establish that for you — and they will do it by looking, which takes about twenty minutes. Every checker in this hub assumes you already know which claim you are testing. This is the only one that treats not knowing as the finding.
Enumeration is unglamorous and cheap. It means searching your own surfaces: the website, product packaging, the last two annual reports, tender responses, sales decks, the careers page, the supplier code of conduct, LinkedIn. Claims accumulate in places sustainability teams do not read, written by people who were not thinking about standards when they wrote them.
None of the rest of this page is possible before that list exists — and once it does, most of the remaining work is routing rather than research.
What this register does not decide
It does not test whether any claim holds. That is deliberate and structural. Each claim is handed to the instrument that governs it, and restating four sets of criteria here would guarantee they drift apart the moment one is revised — making four pages wrong at once instead of one page out of date. The register classifies and routes; the checkers adjudicate.
It does not count. How many claims you make is not a verdict, and a register that reports “four claims” as its answer has told you nothing you did not know. The verdict is about whether the set is enumerated, documented and reviewed.
And it does not assess consumer-protection exposure. Claims that appear in marketing are governed by advertising and consumer regimes — the CMA’s Green Claims Code, the FTC’s Green Guides, the EU Green Claims Directive — that apply their own tests and are entirely separate from the accounting instruments above. This register does not run those tests: each regime has its own thresholds and its own enforcement, and a claim can pass every accounting limb here and still be challenged on how it was presented. Naming the exposure and routing to the instrument is the honest position; guessing at it on a page about greenwashing would be a poor joke.
How we keep this current
The routing on this page is maintained alongside the checkers it points at, so a claim always lands on the instrument that currently governs it rather than the one that did when this was written.
The thing that goes stale fastest is not this page — it is your register. New claims are made by people who have never seen it, usually in a hurry, usually on a surface nobody in sustainability monitors. Re-running this when a campaign launches costs a minute and is the only control that catches a first claim before it becomes an established one.
Checked against corpus edition 2026.284.
Frequently Asked Questions
Because four different instruments govern them, each with its own test, and restating all four here would guarantee they drift apart the moment one is revised — leaving four pages wrong at once. This register asks which claims you make and hands each to the checker that tests it. That split is the reason the individual checkers can stay accurate.
Usually yes, because “we only make one” is a belief rather than a finding until somebody has looked. The most common result of a first enumeration is discovering a second claim on a surface the sustainability team does not monitor — a product page, a tender response, a careers site. If the search confirms one claim, that is a five-minute confirmation and a register you now have.
Anything a reasonable reader would take as an assertion about your environmental performance, wherever it appears. It does not have to be in a sustainability report or use a technical term. A product page saying “climate neutral”, a tender answer claiming renewable power, a slide with an avoided-emissions figure — all of them are claims, and none of them stops being one because it was written by marketing.
It is better than nothing and it answers the wrong question. A folder tells you that support exists somewhere; what gets asked is what supports this specific sentence, and the gap between those two shows up under time pressure. Tying evidence to each claim is what makes it producible on demand rather than reconstructible over a week.
Somebody whose job is to disagree, and not the team that made them. Internal legal or communications review catches a great deal; third-party assurance catches more and carries weight with people outside your organisation. The failure mode this register reports is claims reviewed only by their authors, which is not a review so much as a second reading.
This page makes no claim about that, and neither should anyone selling you a register. What it does is make your position knowable to you before it is knowable to someone else. Consumer-protection and advertising regimes apply their own tests to claims in marketing, and we do not adjudicate them here — that question needs a lawyer rather than a tool.
Whenever a campaign launches, a report is drafted, or a tender goes out — which is to say, whenever a new claim is likely to be made. That is the moment a register stops being current, and it is almost never the moment anyone thinks to check it. The instruments also move: one of the four has already been withdrawn and replaced.
Record that. It sounds trivial and it is the cheapest control available: the common failure is not a bad claim, it is a first claim made by somebody who did not know it was the first. A register with nothing in it establishes that the absence was a decision, and gives the next person drafting a brochure something to check against.