Abstract
Statement of Problem: The transition of the fashion industry to sustainability has led to an increase in environmental claims on marketing materials, product labels and corporate communication. However, such sustainability certification systems lack uniform legal criteria across countries, which facilitates greenwashing.
Research Objectives:
- To explore current legal frameworks regulating eco-claims in major fashion markets.
- To identify structural and enforcement deficiencies that allow deceptive greenwashing claims in the fashion industry.
- To assess the effectiveness of recent legislative measures and formulate a comprehensive legal framework concerning greenwashing claims.
- To analyse consumer psychology concerning environmental claims with regard to fashion products
- To evaluate current certification standards of green claims in the fashion industry and their legal enforceability.
Hypothesis: The lack of a harmonized, binding legal framework defining and verifying environmental claims in the fashion industry creates a regulatory enforcement deficit that facilitates greenwashing and weakens consumer protection law.
Methodology: The study utilizes doctrinal research method, which encompasses comparative legal analysis of environmental marketing regulations in the EU, US, UK, and India and case study investigation of some of the latest greenwashing suits in the fashion industry. It also employs a critical analysis method to analyze and evaluate the law relating to greenwashing in various jurisdictions.
Findings: Findings reveal a big difference in regulations, with the EU’s Green Claims Directive setting a global standard for strict, uniform rules. India, on the other hand, doesn’t have any specific laws against greenwashing, which makes it easy for fashion brands to make false claims. While India’s framework remains underdeveloped, the US model demonstrates the potent deterrence of class action lawsuits, which impose significant financial and reputational costs. India could benefit from both creating strict laws and giving the courts more power to allow similar lawsuits by consumers.
Suggestions: The proposed legal framework encompasses augmented disclosure requirements for the evidentiary foundation of sustainability claims, harmonized cross-border enforcement mechanisms for internationally recognized fashion brands, and stringent penalties in the existing law to promote systemic compliance.
Introduction
Fashion purchasing encompasses cognitive and emotive dimensions (Cho et. al., 2014). Cognitive actions encompass strategic planning, which involves the reasonable assessment of one’s wardrobe and requirements to determine an appropriate item for purchase. Affective or emotional elements encompass pleasure, excitement, guilt, loss of control, and regret. Individuals purchase items to alleviate depressive moods, convey their identity, or simply for pleasure. They provide solace, assistance, and gratification through acquisitions. Individuals engage in compulsive purchasing when they perceive it as socially acceptable. Fashion media and social influencers significantly contribute to public education regarding social conventions. They are concurrently affected by the booming fashion public relations sector (Ekinci et. al., 2025). The fashion industry has a huge impact on this psychological landscape. Marketing doesn’t just sell a product; it sells an ideal, a story, and a sense of self. This story is becoming more and more green as people become more aware of the environment. Not only do consumers want style, but they also want luxury and fulfillment from purchasing things that are beneficial for our planet as well as ethical. This sturdy emotional appeal to be both sophisticated and responsible has popularized the environmental claims as a useful way to advertise products.
But this rise in eco-friendly marketing has also made it easier for producers and traders to deceive consumers (Ummar et al., 2023). As consumers these days are more influenced by social media handles like Instagram and Facebook, where influencer advertising with regard to green products moulds social norms, the brands are using it as an opportunity to showcase their environmental credentials. The fact that many sustainability certifications are voluntary and that there are no clear legal standards across all markets has given rise to an immense regulatory gap (De Freitas Netto et. al., 2020). This disparity has let the deceptive practice of greenwashing grow, in which the emotional appeal of an eco-claim is intentionally detached from its logical and factual basis (Dorfleitner, 2023).
This paper deals with the disjunction between emotional marketing and verifiable facts that constitute not only an ethical shortcoming but also a legal loophole. The law has had a difficult time keeping up with the fashion industry, which is full of green messages. This study delved into the existing laws that are meant to ensure that fashion brands are authentic about their environmental claims. It goes beyond the psychology of desire and looks at the laws against lying in big markets like the EU, US, UK, and India. The study finds important structural and enforcement gaps that let misleading greenwashing continue, looks at the potential of new laws like the EU’s Green Claims Directive, and suggests a complete legal framework to fill the gaps. At last, this research states that strong, uniform legal enforcement is the fundamental prerequisite for safeguarding consumer confidence, fostering genuine environmental innovation, and ensuring that the fashion industry’s green revolution is established on authenticity instead of mere marketing gimmicks.
Deconstructing Greenwashing in the Fashion Context
The fashion industry constitutes around $2.4 trillion and hires about 300 million people around the world(“What is the UN Alliance for Sustainable Fashion?”, 2025). It has a massive impact on environmental resources. It makes up 20% of the world’s wastewater and costs $100 billion a year in lost profits because it isn’t used enough and isn’t recycled (Bailey et. al., 2025). It also causes 9% of the microplastics that leak into the oceans each year (Kounina et al., 2024). The industry makes about 92 million tons of finished goods every year, using up 79 billion litres of water (Centobelli et al., 2022). The carbon emissions from the product life cycle are similar to those of all 28 EU member countries put together and are higher than those of international shipping and aviation (Bildirici et. al., 2025). Fast fashion makes these problems even more unmanageable. As estimated, by 2030, the fashion waste is expected to reach 148 million tons (Chandana S, 2025).
Fashion industries are heading towards more accountable and sustainable measures as consumers are becoming more conscious regarding the products they buy. Also, the approach of lawmakers to exert liability on the fashion brands, ensuring that manufacturing meets carbon emission criteria and reinforcing the production of clothes manufactured through clean technologies, the brands see sustainability as a means to improve their reputation and gain a competitive edge. Some companies, on the other hand, do ‘greenwashing’, which means making environmental claims without really caring about them or being honest about them in order to make their brand look better (Schmuck, 2018). Greenwashing can take the form of symbolic actions that focus on small problems, draw attention away from practices that aren’t good for the environment, or misrepresent real efforts to protect the environment (Terra Choice Environmental Marketing, 2009). The H&M case in 2013, in which claims that products were ‘eco-conscious’ were found to be false and misleading, is a good example of this (Brinquis, 2023).
A lot of green claims around the world don’t have any evidence or reliable information to back them up, which confuses consumers and makes sustainable practices less trustworthy. For example, a report from 2009 said that 98% of products that made green claims were actually greenwashing, and that green advertising was growing a lot (Bender, 2011). The European Commission found that 53% of eco-claims give imprecise, deceptive and unverified information, and 40% of them don’t possess any credible information (“Green claims,” 2025). The rise of sustainability labels with different levels of transparency shows that consumers need standardized and clear practices to help them make decisions.
Greenwashing adversely influences consumers, stakeholders, as well as the environment by making people less likely to believe what companies say and possibly negatively impacting their finances and reputation, even when they are not acting deceitfully. Many certifications and indexes exist within the fashion world, such as the ‘Higg Index’ and ‘GOTS accreditation’, that indicate sustainable practices in the fashion sector (Gonçalves and Silva, 2021). Deplorably, the majority of these initiatives function as sustainability facades for fashion brands, endorsing extensive greenwashing accompanied by a substantial shortcoming in transparency. Moreover, these enterprises frequently employ ambiguous terminology, keywords (e.g., eco-friendly, chemical-free, organic, and sustainable), and strategies to disseminate deceptive marketing communications (Beard, 2008). This perpetuates misunderstandings of environmentally relevant terms and creates a disparity between consumer expectations and the information provided by corporations. The paper, “Synthetics Anonymous: Fashion labels’ Addiction to Fossil Fuels”, analyzed around 50 prominent fashion labels, including ostensibly transparent entities such as Zara, Primark, H&M, and Burberry (Trunk et al., 2023). This study evaluated the quantity of fossil-fuel-derived raw materials in their collections and their pledges to diminish them. H&M, ASOS, and M&S were recognized as the most egregious violators, with erroneous claims of 96%, 89%, and 88%, respectively (“Response: Charging Markets (Letter from Charging Markets to UK Government),” 2021). Additionally, it was found that the so-called eco-conscious collection of one of the leading fast fashion brands, i.e. H&M, comprised a large percentage of synthetics, i.e. 72% in contrast to its main selection (61%)(Riches, 2022).
Asidefrom the presence of certifications and programs to recognize eco-conscious fashion, misleading practices, ambiguous terminology and insufficient disclosures persist, which mislead consumers. It underscores the pressing requirement for improved accountability and a reconsideration of existing sustainability standards within the fashion industry. As global awareness meets the significant adverse effects of climate change, the fashion trade reaches a crucial moment, where the dialogue on sustainability evolves. The fashion trade comes third in the sequence after food, recreation and culture, which significantly exploits our water resources. In 2020, EU-27 homes utilized around 4,000 million m³ of water for the production of textiles (Chen et al., 2021). As per the data ofthe European Environmental Agency, 2022, it is revealed that fashion exploits a large portion of our land, following food and housing, accounting for 400m² per person (European Environment Agency, 2024). The fashion sector, encompassing the entire life cycle of its products, is particularly rapid, leading to significant trash generation in a brief period and contributing to 35% of the main microplastics released into the environment (Aponte et al., 2024). In 2015, 195 countries recognized unified strategic objectives for mitigating carbon emissions under the Climate Protection Agreement (Bee, 2020). As a result, a substantial rise in interest has been observed among consumers in eco-friendly products.
Regulatory Frameworks Across Key Jurisdictions
The fashion industry around the world is incredibly steadfast in sustainability, but at the same time,e there has been a rise in the incidents of greenwashing. Such incidents have led various countries to come up with certain laws and guidelines to combat this unethical trade practice. Such regulations are based on three important ideas, e.g. specificity, evidence, and integrity. The European Union is becoming the undisputed leader, building a strong legal wall that goes beyond reactive enforcement to proactive, standardized rules. ‘The Unfair Commercial Practices Directive (UCPD)’, which bans misleading business practices, is at the heart of its approach (“Unfair commercial practices directive,” 2005). A document which was released by the European Commission in 2021 made it unequivocal as to how UCPD should be used to publish any environmental claims. It stated that all claims must be correct, precise, explicit, and backed up by strong, certifiable scientific evidence. It also warned against vague, unqualified claims like ‘eco-friendly’. ‘The Empowering Consumers for the Green Transition Directive’, which was passed in February 2024, bans fashion brands from making any unsubstantiated claims in the form of terms like ‘eco-friendly’ or ‘sustainable ‘ unless they can provide any concrete evidence to prove their claim (Bank, 2024). This EU directive is expected to be enforced on September 27, 2026. The Green Claims Directive, which was proposed in March 2023, also wanted to make a consistent, detailed way to prove claims. It said that companies had to do a full life-cycle assessment and show proof for every claim, with independent verification and a QR code for easy digital linking (Bank, 2024). However, this directive faced political criticisms that led to a temporary hold in June 2025. As of August 2025, there had been no final adoption, which leaves a gap in the originally envisioned directive. Progress is still being made through the Empowering Consumers Directive and existing UCPD enforcement. Therefore, such directives as well as legislative frameworks are being introduced to put the burden of proof firmly on the fashion brands.
The United States of America, alternatively, has a more decentralized and litigation-heavy legislative framework to deal with greenwashing (Lorance, 2010). Such a system is mostly regulated by the Federal Trade Commission (FTC) and its Green Guides. The Green Guides are not laws, but these are proposals that elucidate how the FTC sees existing law under Section 5 of the FTC Act, which prohibits misleading advertisements (Rotman and David-Pennington, 2024). The strength of the FTC Act comes from the fact that its provisions give a comprehensive as well as claim-specific assistance. For example, explaining when a fashion product can be considered as ‘recyclable’ or ‘compostable’, etc. The provisions largely empower the FTC to prevent any unfair methods of competition in the market. However, the effectiveness of such a law has remained debated because of the several ambiguities in its provisions. Likewise, because these provisions haven’t been updated since 2012, there are huge gaps, especially when it comes to terms like ‘sustainable’ or ‘natural’. This Act does not clearly define the meaning of such terms. As a result of the weak enforcement of the FTC Act, the FTC started reviewing its ‘Green Guides’ again in December 2022. As of August 2025, no changes have been made because the new administration has other things to focus on (Basila, 2024). Enforcement mostly happens after the fact, through FTC investigations and civil penalties, or through expensive private class-action lawsuits where consumers say they were tricked into buying something by false advertising. Several lawsuits have been filed against vendors for making ambiguous eco-claims about the sustainability of rayon or recycled polyester. The recent actions of the FTC comprise settling with big stores in 2024 and 2025 over false claims. It shows that the FTC is taking a tougher stance, especially on claims about ‘recyclability’ and carbon offsets (Qanbar, 2025). Therefore, the US laws and regulations are still a combination of federal guidance and state laws. It relies on the threat of enforcement actions and lawsuits instead of pre-existing legislative standardization.
If we talk about the United Kingdom, after Brexit, it is at a regulatory crossroads. The UK is still using a system that is similar to the one it had when it was part of the EU. The Competition and Markets Authority (CMA) is the main enforcer of greenwashing law in the UK. It derives its powers from the ‘Consumer Protection from Unfair Trading Regulations 2008’(Romata et al., 2023). One of the major steps of CMA in implementing the greenwashing law in the UK is publishing the ‘Green Claims Code’. The green claims code is based on principles similar to the UCPD guidance of the European Union (Feijao et al., 2021). This code states that environmental claims must be accurate, honest and must prove the authenticity of such claims, taking into consideration the full product lifecycle. The CMA has backed this code by thoroughly inspecting the fashion brands and launching investigations into their green claims (Nagode, 2023). They have also made changes to make sure that companies follow the rules. ‘The Digital Markets, Competition and Consumers Act, 2024’, which was enforced on January 1, 2025, as well as on April 6, 2025, entrusts the CMA with the power to levy fines, i.e. up to 10% of the global turnover of the fashion company involved for contravening consumer law (Borthwick et al., 2025). Within this Act, the CMA can exercise its powers without referring the case to the courts. This change from a litigation-based to an administrative penalty-based model implies that the UK is moving toward a sturdier, EU-style enforcement system. It also suggests that the UK may want to position itself as a leader in the fight against greenwashing, even though it is going in a different direction than some EU laws.
India has made a huge and proactive move in South Asia by becoming a regulatory leader in the developing world. The Central Consumer Protection Authority (CCPA), as provided under the Consumer Protection Act, 2019, released the ‘Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024’ on October 15, 2024, following a draft that was released in February 2024 (Kishwar et al., 2024). Within such guidelines, the CCPA has introduced the important notion of ‘comparative claims’, which means that any environmental benefit claimed must be explicated in terms that an average person could understand (Bhat and Mohanta, 2025). For instance, instead of saying that ‘a number of percentages of electricity’ has been saved while manufacturing a particular piece of cloth, they should say about the ‘units of electricity’ which were saved. The CCPA straightforwardly address the issue of carbon neutrality by requiring that any such claim be substantiated by clear and specific information about the carbon credits bought, their source, authenticity, and ownership (Kaur, 2024). As per the guidelines, the businesses should also make it clear what the difference is between offsetting and reducing the product’s actual emissions. The rules also follow a principle of totality, which means that companies have to make sure that any specific green claim about an attribute doesn’t give the wrong idea about the product’s overall environmental impact. For example, a small recycled thread can’t be used to suggest that a garment is completely ‘sustainable’. They also require a ‘reliability’ test, which means that all claims must be true for the entire life of the product and under normal use conditions. They also don’t allow the use of misleading visual elements, like green logos or pictures of nature, that could make it look like the product has an environmental credential. The Consumer Protection Act of 2019 gives the CCPA the power to punish violations with large fines (up to INR 10 lakh for first offences and INR 50 lakh for repeat offences) and even jail time for repeat offenders (Ministry of Consumer Affairs, Food & Public Distribution, 2025). This makes India’s enforcement mechanism, in principle, as good as the best ones in the world, but its effectiveness in practice will depend on consistent enforcement.
Bangladesh and Sri Lanka, both countries, are emerging as major fashion manufacturing hubs that are still in their early stages of developing their legal regulations with regard to textile manufacturing (Das and Hewalage, 2025). As of August 2025, their legal frameworks are generally based on broader consumer protection laws and are just guidelines rather than imposing any stricter penalties for making false fashion eco-claims. They don’t have any specific, legally binding rules against greenwashing. For example, Bangladesh’s main organization, the Bangladesh Standards and Testing Institution (BSTI), is more concerned with product quality and safety standards than with marketing claims (Ala Uddin, 2025). However, the pressure from international brands and export markets, especially the EU and the USA, reveals that such pressure is compelling Bangladeshi manufacturers to adopt environmentally friendly processes and be more transparent about their eco-claims. This makes it so that local supply chains follow global standards even when there aren’t strict laws in place in the country. This means that the EU’s Empowering Consumers Directive has an effect on South Asian manufacturing even though it doesn’t have any laws in place.
Greenwashing and Consumer Protection Laws: A Jurisprudential Critique
Experience of the fashion industry with greenwashing law in various places around the globe reveals a fundamental conflict between the aspirational language of marketing and the legal requirement for certifiable truth. Consumer protection law, which was originally meant to stop upfront deception, is now in charge of a much murkier area: the implied promise of ecological virtue. The European Union, the United States, and India all have different ideas about how to govern this space. The EU’s approach is to standardise truth ahead of time, while the US’s approach is to react to lawsuits, and India’s new guidelines are more declarative and paternalistic.
The EU’s approach is a kind of legal instrumentalism, which means that it uses the law as a proactive tool to build a green market that people can trust. If the Green Claims Directive, which was brought up in 2023 in the European Union, were to become law, it would go beyond punishing deceptive advertising as it proactively defines environmental integrity through standardised Life Cycle Assessment (LCA) methodologies (Riordan, 2024). Environmental integrity in the fashion sector means minimizing the adverse impact of textile manufacturing by adopting responsible sourcing, minimizing waste, reducing water usage as well as pollution and promoting recyclability of the textiles. This directive, therefore, puts a positivist legal framework on the subjective world of sustainability, making it conceivable for claims to be assessed in a legally binding way. It puts all the responsibility on businesses to prove their claims, requiring that any green claim be verified by a third party and made available online before a product can even be sold. This is a social democratic idea in which the government shapes the market to protect the common good and make sure that consumers have a real ‘right to know’.
Alternatively, the United States of America runs on a model of consumer sovereignty that is driven by legal realism and adversarial litigation. The Green Guide launched by the FTC are not a law that must be trailed, but they do show how the agency plans to enforce them (Basila, 2024). There have been no amendments to it since 2012, despite a review that started in 2022. However, the Green Guides represent a robust protection of consumers against deceptive fashion eco-claims because it heavily penalizes the fashion companies through class-action lawsuits. This particular code is in tune with the neoliberal idea that lawsuits and pecuniary damages act effectively in order to check the deceptive marketing of fashion articles. But this system naturally favors going after giant, wealthy brands and claims that are clearly false instead of just vague ones. It also acts as a minimalist state approach that inflicting the fashion brands from litigation will deter them from making any false environmental claims. This often fails to address more subtle forms of greenwashing because it is hard to win a lawsuit.
‘Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024’ in India depicts that the government is taking a strong stand against false eco-claims in the fashion sector (Kishwar et al., 2024). These guidelines are based on the Consumer Protection Act of 2019. The Central Consumer Protection Authority (CCPA) is the state’s way of saying that it is a protector. The guidelines are strong because they make specific rules against things like ‘eco-friendly’ or ‘green’ claims that aren’t true, require clear information about whether a claim applies to the product or just its packaging, and check the use of green imagery (like leaves or earth tones) that might suggest a false virtue. This is not the EU’s way of making the truth, but a sovereign claim of power to make the story easier to understand and keep people from being manipulated. Therefore, it links consumer law directly to social justice.
Important Case Laws in Fashion Greenwashing
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Abraham Lizama, et al. v. H&M Hennes & Mauritz LP:
H&M’s ‘Conscious Choice’ collection purportedly comprises clothing manufactured from eco-friendly materials. However, H&M’s claim is false, as alleged by the plaintiff in this class action lawsuit (Shendruk, 2022). The plaintiffs said that the environmental scorecards that came with products (like ‘This garment is made with 20% less water’) were misleading because they were based on an internal, undefined benchmark instead of a standard that could be checked by the industry (Rizzi, 2022). The suit claimed that this was not just a harmless lie, but a planned ‘marketing ploy’ to justify high prices and attract environmentally conscious customers. The court threw out the case in May 2023, saying that the relative claims (like more sustainable) were not inherently misleading. This case directly questioned the legality of self-defined, relative claims, which are the very basis of fashion greenwashing. The dismissal set a precedent that internal, comparative data can suffice if not outright false, but it has spurred calls for stricter external standards, influencing how brands approach substantiation in ongoing regulatory discussions.
- Dwyer v. Allbirds Inc.:
In this class-action lawsuit, Allbirds deceived consumers by making a false claim stating that its ZQ-certified merino wool shoes were ‘sustainable’ without disclosing the complete details about the full product lifecycle and manufacturing process (Shaak, 2022). It was upheld that the eco-claims of the subject brand were found to be false. In June 2022, the case was thrown out.
This case got to the bottom of the philosophical issue of greenwashing- is there really a product that can be called ‘sustainable’? It made the law think about whether broad, absolute claims can ever be proven true or if they are always false advertising. The dismissal exposed how important it is to use an unambiguous terminology as required under EU guidelines. It also displayed how the inclination is moving away from broader terms and toward specific, certifiable traits such as ethically sourced wool or grazed on regenerative land. In 2022, the Competition and Markets Authority of the UK started examining ASOS, Boohoo, and Asda (including George at Asda) for potentially making dishonest claims about being ecologically friendly. This could have led consumers to have confidence that those products were better for the environment without any obvious proof (Neate and Butler, 2022). The enquiry ended in March 2024 with no monetary penalty. Later on, the companies signed an agreement to make their environmental claims explicit. In this suit, the CMA acted as a watchdog on its own, contrasting the US litigation model. This suit makes it clear that regulators are not merely scrutinising the product tags but are meticulously examining the whole digital marketing process that fashion brands employ to advertise the eco-friendly nature of their products.
Conclusion
The evolution of a legal regime to deal with greenwashing in the fashion industry marks an end to the time when people could make deceptive environmental claims. The preventive standardization approach of the European Union through its regulations like the Unfair Commercial Practices Directive and the Empowering Consumers Directive, the litigious enforcement through the Green Guides and class-action lawsuits in the USA, and the proactive investigations by the Competition and Markets Authority in the UK, are creating a multi-faceted response to the complex issue of greenwashing. The ‘Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024’, formulated by CCPA in India, is a commendable move (“Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022,” 2022). It displays how India is coming out as a regulatory leader in the Global South. However, there is a long way to go to convert these guidelines enacted in various parts of the world into a stricter law against greenwashing. Especially for India, in order to reach its full potential, it requires moving beyond basic guidelines and creating a comprehensive code to penalize the phenomenon like greenwashing. The Bureau of Indian Standards and the CCPA could work together to create such a set of standards to deal with deception in fashion marketing. This would ensure that the brands follow a verifiable system of measurement instead of skewed marketing. Enforcement should become a multi-stakeholder ecosystem, with dedicated technical teams strengthening the CCPA and encouraging consumer groups and NGOs to file representative lawsuits under the Consumer Protection Act. This will promote shared vigilance. A centralized digital portal for the public to report false fashion claims would make the market more accountable.
India’s strategy should introduce sterner punishments for deceptive marketing, with the possibility of imprisonment for recurrence of misleading claims by the fashion brands. However, a government-recognised seal for claims verified by accredited third parties could help real, sustainable brands and build trust among consumers. Global South nations like India, Bangladesh and Sri Lanka, which are emerging as a major manufacturing epicentre in the world, need to make sure that their legal framework supports smaller producers to meet global standards by giving them access to clean technologies and compliance advice. This would ensure verified sustainable manufacturingas a high-value export. These countries should bring up a new enforcement model that protects consumers, permits ethical trade, and makes greenwashing law a global standard for environmental integrity by combining the rigorous standards of the EU, the market-driven accountability from the USA, and the proactive oversight of the UK. This may convert the promise of sustainable fashion into a reality.
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Author: Saumya Verma
