Communicating sustainability: truthfulness, reputation and defensible claims

To communicate sustainability without risk you need to state precisely what you have done, within what scope, with what data and who verified it. From 27 September 2026 vague claims and self-made labels are prohibited, but caution does not mean staying silent: it means building specific messages and keeping the evidence. Here you will find the labels you can use, how the AGCM (the Italian Competition Authority) works and a five-step method for claims that stand up in front of customers, competitors and authorities.

Why truthfulness has become a reputation issue

For years environmental communication was treated as marketing: positive words, green colours, a few leaves in the logo. Today an environmental claim is a statement with legal and, above all, reputational consequences. A public challenge weighs more than the fine: a social media crisis, customers asking for explanations, competitors filing complaints, banks and investors revising their assessment.

The risk applies even when the company has genuinely invested in sustainability. A real result told badly, for example extended to the whole company when it concerns a single plant, becomes greenwashing just like an invented one. Conversely, a precise message, even a modest one, builds trust over time.

The underlying rule is simple: caution does not mean saying less, but saying it precisely. Those who disappear from the debate out of fear, so-called greenhushing, miss the opportunity to get credit for what they have actually done.

What makes a claim defensible

Authorities assess the overall impression the message creates in the consumer, not just the words: images, symbols, colours, omissions and placement all count. A claim holds up when it answers five questions.

The percentages in the table are examples. A percentage reduction without a base year, scope and absolute starting value says nothing, and readers know it. The same applies to climate claims: offsets no longer allow a product to be declared neutral, as explained in the article on carbon neutral and what you can claim.

Sustainability marks and labels: which ones you can use

Under the new rules, a sustainability label, i.e. a voluntary mark relating to environmental or social characteristics, is allowed only if it is based on a certification scheme or established by public authorities. The certification scheme must be open to all traders on transparent terms, have criteria developed with experts and stakeholders, provide procedures for non-compliance and include monitoring independent of the scheme owner.

In practice, the little leaf logo designed by the marketing department can no longer be used as a label. Here is where the most common tools stand:

For construction products and materials, the EPD remains the most robust tool: it does not say a product is “sustainable”, it provides comparable figures the customer can use.

AGCM risks and more

The Italian Competition Authority (AGCM) applies the Consumer Code to communications aimed at consumers. It can open investigations, order the practice to stop, accept commitments from the company and impose fines of up to 10 million euros. In 2025 it fined the operator of Shein’s European website 1 million euros, finding the claims on circularity and recyclability untrue or confusing and the emission reduction commitments contradicted by the data.

The risk does not end with the AGCM:

• Business-to-business communication. Directive 2024/825 protects consumers, but in B2B relationships the rules on misleading advertising (Legislative Decree 145/2007) still apply, again enforced by the AGCM.
• Self-regulation. The IAP Code of Marketing Communication Self-Regulation requires declared environmental benefits to be based on truthful, relevant and scientifically verifiable data. The rulings of its Jury are quick and public.
• Competitors. A competitor can challenge a claim in court for unfair competition or report it to the authorities.
• Professional customers and banks. Anyone who receives a claim in a specification, a questionnaire or a tender compares it with the data: an inconsistency costs credibility for years.

The proposed European Green Claims Directive, which would have imposed prior verification of claims, stalled in 2025 and is not law today. Its approach, with specific claims, scientific evidence and independent verification, nonetheless remains a good model of caution. The rules already in force are summarised in the article on the new rules from 27 September.

A five-step method

The companies that communicate best do not have better copywriters: they have a process. Here is a framework that works for an SME too.

1. Start from the data. First ask yourself what you can prove, then what you want to say. The message comes from the data, not the other way round.
2. Open a dossier for each claim. Data source, calculation method, scope, limitations, any external verification and the claim’s expiry date.
3. Get approval from several functions. Significant claims go through sustainability, marketing, legal and management. Delegating to an agency does not shift the responsibility.
4. Review on a schedule. A 2023 figure does not support a claim in 2027. Set a review at least once a year, alongside the data update.
5. Make the evidence accessible. A page with more detail or a QR code leading to the method and data strengthens the message instead of weakening it.

The dossier works if the data is already in order. An ESG report under the VSME standard is a good starting point, because it gathers consumption, emissions, waste and social indicators in a single document using a recognised method. With Envify you can keep every value linked to its source document, such as the utility bill or the waste form (FIR), so the evidence is already there when someone asks for it.

From vague claim to defensible claim

All values are examples: in your communication use only figures you can document. Note that the better versions are longer and less catchy, but they are the ones you can repeat without fear in front of a customer, a journalist or an official. That is what, over time, builds a company’s sustainability reputation.

Frequently asked questions