Green Claims and Greenwashing Risk in India

Yes, greenwashing is regulated in India. The Central Consumer Protection Authority has issued guidelines under the Consumer Protection Act 2019 on misleading environmental claims, and a vague or unsupported claim such as 'eco-friendly', 'natural', 'plastic-free' or 'carbon neutral' can be treated as a misleading advertisement or an unfair trade practice. The CCPA can order the claim withdrawn or changed and impose penalties, consumers can go to consumer commissions, competitors complain to ASCI, and listed companies face SEBI's disclosure rules. A green claim needs evidence before it is published, not after someone asks.

This guide is for brand owners, manufacturers, marketing teams, listed companies and the agencies and influencers who promote them, and for consumers who suspect a green label is hollow. It explains which rules apply, what makes a claim risky, how environmental law and pollution records feed into greenwashing disputes, and how to check a claim before it goes out. It is part of our series on thermal power, industrial accidents and business risk.

Green claims often rest on environmental compliance: an EPR target met, a zero liquid discharge plant, a clean consent record. If the compliance is shaky, so is the claim. That link is why we cover this topic alongside guides such as legacy contamination in acquisitions.

The essentials

Is greenwashing illegal in India?

A misleading green claim is unlawful in India, even though no single statute is called a greenwashing law. The Consumer Protection Act 2019 prohibits misleading advertisements and unfair trade practices, and gives the Central Consumer Protection Authority (CCPA) power to investigate, order an advertisement discontinued or modified, and impose penalties. In October 2024 the CCPA issued the Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, which spell out how those general rules apply to environmental claims.

The guidelines apply to environmental claims made in advertisements and on products and services, and to the businesses, advertising agencies and endorsers behind them. Their thrust is simple: environmental claims must be accurate, specific and backed by verifiable evidence, generic terms need qualifiers, material information must not be hidden, and aspirational claims about the future need actual plans. Read the current text before finalising a campaign, because the detail matters and guidance in this area keeps developing.

Beside the CCPA sit other routes. Consumers can file complaints of unfair trade practice before district, state or national consumer commissions. The Advertising Standards Council of India (ASCI), a self-regulatory body, has its own guidelines on environmental claims and hears complaints from competitors and the public. Listed companies face SEBI's disclosure rules. And sector rules, such as the labelling requirements for compostable and biodegradable plastics, apply on their own terms.

What counts as greenwashing?

Greenwashing is making a product, service or company look better for the environment than it really is. It rarely involves an outright lie. More often it is a broad word doing more work than the facts allow ('eco-friendly' on a product where only the outer carton is recycled paper), a true but cherry-picked fact (a 'low carbon' shirt that is low carbon only in one stage of production), or a picture that suggests something the words do not say (leaves, forests and earth tones on an ordinary plastic product).

Other common patterns are claims about a whole product that apply only to part of it; claims of 'recyclable' where no collection or recycling system actually exists for that material; 'free of' claims about substances the product would never have contained anyway; made-up or self-awarded seals and badges; and 'carbon neutral' claims that rest on purchased offsets without saying so. Each of these misleads the ordinary consumer, which is the test that matters under consumer law.

Corporate claims count too. A company describing itself as 'committed to zero discharge' or 'a green manufacturer' in its advertising, website or investor materials is making a representation. If its plant has an open closure direction or a history of effluent violations, that claim is both a consumer law risk and a gift to anyone litigating against the company.

Packaging and product are a frequent source of confusion. A claim on the front of a pack is read as a claim about what is inside, unless the wording makes clear that only the packaging is meant. Spell out which one you are talking about.

Common green claims, the risk, and what you need to support them

The rules that apply to green claims

Why pollution records and EPR compliance matter to green claims

Many green claims are really claims about environmental compliance, and compliance is a matter of public record. A brand that says its packaging is 'responsibly recovered' is relying on its EPR obligations being met. A textile company that advertises 'zero water pollution' is relying on its zero liquid discharge system working and its consent conditions being met. If the CPCB portal shows an EPR shortfall, or the State Board has issued a show-cause notice, the claim is contradicted by the regulator's own documents.

EPR deserves particular care. Meeting EPR targets under the Plastic Waste Management Rules is a legal obligation, not a voluntary green achievement. Marketing ordinary compliance as 'plastic neutral' without explaining it invites challenge, and certificates bought from unreliable sources carry their own risk if they are later found to be invalid. Our guides on who needs plastic EPR and EPR certificates and target shortfalls explain the obligations.

In environmental litigation, a company's own green claims are often exhibits. Residents who take a factory to the NGT will put its sustainability report next to the joint committee's inspection report. Advocate B.K. Singh has seen this from both sides: claims that a unit 'recycles every drop' sit badly beside a sample report showing effluent in a drain, and tribunals notice the gap.

Carbon neutral, net zero and offsets: what can you say?

Carbon claims attract the most scrutiny because they are the hardest for a consumer to check. A 'carbon neutral' product usually means the company estimated the product's emissions and bought offsets to balance them. That is not unlawful, but saying 'carbon neutral' without explaining that it relies on offsets, which offsets, and what boundary the calculation used, is the kind of claim the CCPA guidelines target.

Net zero targets are claims about the future. They should come with a dated plan, interim milestones and a clear statement of what is and is not covered. A slogan with a year attached and nothing behind it is the textbook aspirational claim the guidelines warn about.

India now has a compliance carbon market under the Carbon Credit Trading Scheme, and separately the Green Credit Programme for activities such as tree plantation and water conservation. These are distinct systems with different purposes, and neither should be described loosely in marketing. Our guide on the carbon credit trading scheme and our page on the Green Credit Programme explain what each actually involves.

How to check a green claim before you publish it

Received a CCPA notice or an ASCI complaint about a green claim?

Respond on time and with evidence. A CCPA notice usually asks for the basis of the claim and gives a short period to reply; an ASCI complaint gives the advertiser a chance to defend the claim before its complaints council decides. In both, the strongest reply is the substantiation file that existed before the claim was published, not a report commissioned after the complaint arrived.

If part of the claim cannot be supported, it is often better to say so early and modify the advertisement, while defending the parts that are true. Regulators tend to treat a prompt, voluntary correction differently from a claim defended to the end and then found misleading. Keep the response consistent with what the company has told the State Board and the CPCB, because inconsistencies between filings are easy to spot.

Check who else is exposed. Advertising agencies, endorsers and sometimes the retailer or online marketplace listing the product will have received the same complaint or will be asked questions. A coordinated reply avoids one party contradicting another.

How to complain about greenwashing in India

If you think a green claim is false or misleading, keep a copy: a photo of the pack, a screenshot of the advertisement or post with the date, and the receipt if you bought the product. Then choose the route that fits what you want. To get the claim stopped, complain to ASCI or to the CCPA; the CCPA can also be approached through the National Consumer Helpline. To get compensation for yourself, file a consumer complaint before the district consumer commission, which can be done through the commissions' online filing system.

Be specific. 'This brand is greenwashing' achieves little. 'The pack says 100% recyclable, but the pouch is a multi-layer laminate and the brand gives no evidence of any recycling route' gives the regulator something to act on. If the claim is tied to pollution, such as a factory advertising zero discharge while discharging into a local drain, the pollution itself should go to the State Pollution Control Board, and if necessary to the NGT, as a separate matter.

Before any green claim goes live

Sustainability reports and investor communications

For listed companies, the risk is wider than advertising. BRSR disclosures, annual reports, investor presentations and green bond documents all describe environmental performance, and they are read by investors, lenders, rating agencies and litigants. A figure in a BRSR that cannot be traced back to plant records, or a reduction claim that ignores a plant that was shut by the board for part of the year, is the kind of discrepancy that surfaces in an assurance review or a dispute.

The practical answer is to treat the sustainability report as a compliance document, not a marketing one. Environmental data should come from the same records the company gives the State Board: consent conditions, monitoring results, hazardous waste returns, EPR filings. Our ESG and BRSR advisory page covers how we help companies align those records. Companies preparing for a deal should also read our guide on environmental due diligence for industrial sites, because buyers increasingly test green claims against site realities.

Mistakes companies make with green claims

The biggest is letting marketing write environmental claims without anyone who knows the compliance position seeing them. The second is copying claims from international campaigns, which may rest on recycling systems or certifications that do not exist in India. The third is assuming that because a claim was not challenged last year, it is safe; regulators and competitors are paying far more attention now.

Companies also overlook the plant. A brand can have flawless packaging claims and still be exposed if its factory has a pending closure notice, an unpaid compensation demand or a residents' case in the NGT. Advocate B.K. Singh's advice to companies planning a green campaign is to run an environmental compliance check on the plants concerned first, and to launch the claim only once the record supports it. Our environmental compliance audit and corporate environmental lawyer pages describe that work, and our guide on plastic ban violations covers the separate risk of selling banned single-use items.