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Introduction
With the Green Claims Directive currently at a standstill, the initiative meant to bring long-needed clarity to environmental communication is now suspended, held back by political tensions over provisions considered too heavy for small and medium-sized enterprises.
At first glance, this might sound like a relief for brands. But in practice, it creates a vacuum, one that collides with ever-growing consumer expectations.
And if we want to avoid repeating the same mistakes, we need to look back.
When, once upon a time, bold commitments had become the new black. When “eco-responsible,” “climate-friendly,” and “conscious” statements took over lookbooks and product pages, rarely backed by proof. When ambition blurred into overstatement, and a lack of definitions or legal standards left the door wide open to greenwashing.
That moment in time triggered a backlash. And that backlash sparked regulation. Not to punish ambition, but to establish a minimum standard of credibility.
Today, that regulatory framework is at a standstill. And brands are left to navigate without it.
So how can they communicate progress without falling into the same traps?
Let’s find out.
Communicating responsibly in fashion, part one: From loud to silent
Let’s rewind.
To fully understand how to avoid the green communication trap, it’s essential to first grasp where it comes from.
If we consider the fact that brands went from claiming their commitments loud and proud to burying them deep in the “CSR” tab of their corporate websites, one thing becomes clear: Somewhere along the way, they lost confidence in what they could say, and how to say it safely.
The birth of green communication
Between 2015 and 2020, as sustainability rose on the public agenda, fashion brands started to respond, with words before systems.
Communicating about impact became a way to stand out, signal values, and respond to growing consumer expectations. Terms like eco-responsible, green, ethical, planet-friendly, and sustainable began to appear in lookbooks, product pages, newsletters and window displays.
Campaigns even featured natural imagery, climate-positive tones, and reassuring narratives; often without much detail to support them.
It wasn’t always malicious. In most cases, brands were only trying to express their intentions.
But in the absence of clear definitions or legal guidance, intentions blurred into marketing language, and marketing language turned into potential overstatements.
And that trend didn’t go unnoticed.
The Fashion Transparency Index, published annually by Fashion Revolution since 2017, consistently highlighted a growing gap between what brands claimed and what they could actually prove in terms of supply chain data, materials traceability, or environmental impact reporting.
In parallel, a 2021 report from the Changing Markets Foundation showed that nearly 6 in 10 green claims in fashion were vague, unsubstantiated, or potentially misleading.
And the European Consumer Organisation (BEUC) warned that this lack of clarity was feeding consumer distrust and confusion.
So, what was missing?
- A shared vocabulary,
- A common baseline,
- A standard of proof.
Green communication was born in good faith. But it grew up in a vacuum.
The rise of legal accountability
Between 2021 and 2024, a series of regulatory moves began to reshape the landscape of green communication in Europe.
- In May 2022, the revision of the Unfair Commercial Practices Directive (UCPD) [Directive 2005/29/EC] made misleading, vague or unsubstantiated environmental claims explicitly illegal.
The revised directive now includes environmental impact and durability under deceptive commercial practices.
- In March 2023, the European Commission proposed the Green Claims Directive: a potential game-changer for environmental communication. It aimed to require that any environmental claim (at the product or company level) be specific, science-based, and independently verified. However, in June 2025, the proposal that was supposed to move forward has been stopped in its tracks, and negotiations have been stalled.
- In February 2024, the Empowering Consumers for the Green Transition Directive was formally adopted by the European Parliament.
It requires companies to provide clear, reliable, and comparable information on product durability and environmental performance. Member States must transpose it into national law by early 2026.
Meanwhile, enforcement was already picking up speed.
In France, the DGCCRF began issuing warnings and sanctions as early as 2022 against brands using terms like “carbon neutral,” “eco-friendly” or “climate positive” without clear methodology, time horizon, or traceable data.
Across Europe, NGOs and watchdogs challenged marketing campaigns they deemed misleading (genuine intentions or not), if proper documentation was missing.
Within just a few months, the message was clear: words that once built trust were becoming potential liabilities.
The great pullback
The regulatory shift had a chilling effect.
As rules tightened and enforcement ramped up, brands didn’t just adapt. Many withdrew.
A 2022 report by South Pole revealed that 1 in 4 companies with net-zero targets chose not to communicate them, mainly due to fear of being accused of greenwashing.
Across the fashion industry, this trend was visible: Product descriptions were simplified, sustainability pages were scaled back, and messages were diluted, or deleted.
Not because actions had stopped, but because the risk of saying too much felt greater than the benefit of saying anything at all.
This was no longer a strategic silence. It had become a defensive one.
Communicating responsibly in fashion, part two: When silence backfires
While greenwashing became a reputational threat, greenhushing quickly settled in as its safer, quieter cousin. For many brands, not communicating at all seemed like the most rational answer to a suddenly high-stakes environment.
But now, let’s come back to the present.
Nearly a decade after sustainability became the new marketing frontier, and two years after regulation began catching up, a strange paradox has taken shape: brands are acting more, and saying less.
The visibility gap
From the outside, it may seem like the sector is slowing down. In reality, many companies are moving forward: They’re switching to certified materials, launching take-back programs, mapping their supply chains in detail. Some are rolling out repair services, others are piloting decarbonisation plans or aligning their sourcing strategies with science-based targets.
But in public? Radio silence.
According to the Fashion Industry Charter for Climate Action, nearly 70 global fashion brands have now pledged to reach net zero by 2050. In France, the “repair bonus” has already supported more than 800,000 product repairs in a single year, a clear signal of institutional and consumer support for durability. Circular platforms like Vestiaire Collective openly communicate their impact, claiming up to 90% fewer emissions when buying second-hand.
And yet, the brands enabling these changes are often the least vocal.
Even more striking: upstream actors like raw material suppliers, recyclers or certifiers are now the most active voices in sustainability storytelling. It’s not necessarily because they do more, but rather because the legal constraints they face seem more indirect. In this imbalance, a strange dynamic has taken hold: suppliers talk, consumers listen, and brands vanish from their own narrative.
The transparency shift
This growing silence would be surprising in any context, but it’s particularly striking in the face of rising consumer expectations.
According to the 2025 KPMG x FMC report, 65% of French consumers now consider a brand’s environmental commitment a key factor in their purchasing decisions. 40% actively prefer brands that enable more responsible behaviours. Among women, nearly two-thirds say they’re willing to pay more for garments produced in a socially responsible supply chain.
People aren’t looking for perfection, they’re looking for clarity. And silence, contrary to popular belief, is not a neutral stance. It creates confusion, opens the door to doubt and most importantly, it comes at a cost.
The illusion of safety
When a brand doesn’t tell its story, someone else eventually will. Without a consistent, credible narrative, trust erodes, consumers lose their reference points and partners begin to question coherence. Internally, teams disconnect from progress they no longer see: invisibility doesn’t read as prudence, it reads as disengagement.
Impact efforts that go unseen also fail to deliver strategic value. They don’t support marketing, don’t strengthen employer brand and don’t justify positioning. And in a market where differentiation often hinges on transparency, what isn’t communicated can’t set you apart.
Of course, caution was understandable: the backlash against greenwashing was necessary and clearer rules were long overdue. But the answer can’t be silence forever. Fear may have been a short-term reflex, but it cannot become a long-term strategy.
Because if saying too much might get you in trouble, saying nothing will make you irrelevant.
Communicating responsibly in fashion, part three: Escaping the trap by turning action into proof
The fear of overpromising is real. The threat of reputational damage is real. But so is the need to move forward.
Today, especially with the Green Claims Directive on pause, brands can no longer afford the comfort of silence or the risk of empty promises. What’s needed now is not more noise, but sharper focus: a way of speaking that is clearer, more grounded, and built to last.
Escaping the green communication trap doesn’t begin with bold slogans or feel-good videos. Communicating sustainability today is less about storytelling than about structuring and data: it begins with internal alignment and methodological clarity.
The good news? Many brands already have more to say than they think. What’s often missing isn’t substance, it’s a framework for expression. And instead of overreaching, brands should start by communicating on solid, verifiable and contextualised initiatives.
Laying the groundwork: Building the backbone of credible messaging
Before communicating any sustainability claim, brands need internal clarity: not just on what they do, but on what can be explained, evidenced, and assumed publicly. This preparation phase is critical to build a safe and coherent message.
Here are three essentials:
- Clarify what exists and why: Map current initiatives — certifications, traceability tools, ESG dashboards — and clearly separate what’s mandatory from what’s voluntary. This helps frame messages accurately, without confusing obligation with commitment.
- Ground every message in evidence: No claim should go public without solid proof: clear data, scope, methodology, and known limitations. If it can’t be substantiated, it shouldn’t be said.
- Align teams and define priorities: Legal, sustainability, product and comms must share the same vocabulary and validation process. Focus first on low-risk, well-documented actions (e.g. durability, repair, verified traceability), and set rules on what can be shared now vs later.
From action to expression: What to communicate, and how
Once the structure is in place, brands can move from intention to visibility. That doesn’t mean saying everything. It means saying what matters, and saying it well.
Traceability can highlight the logic behind sourcing decisions (provided those decisions aren’t simply restatements of legal obligations). What matters is what the brand chooses: supplier mapping, audit frequency, or multi-tier visibility. Certifications add weight when they’re explained, not just named. If a label applies only to a component or to a step, it should be made explicit. The value isn’t in the acronym: it’s in the transparency around it.
Supply chain transparency is often misunderstood as a regulatory burden. But when shared with clarity, it becomes a sign of commitment. Which tiers are monitored? What are the criteria? How does the brand respond to issues? Even when the supply chain is complex, a simple explanation of the approach builds credibility.
Durability is one of the most underused levers. Testing abrasion, reinforcing key seams, designing for repair: all are technical decisions with environmental value. With the ESPR making many of these requirements mandatory, what can be communicated must go beyond the legal baseline. What’s tested? What threshold is met? What effort was made? That’s where the message lies.
Repair and after-care show care in action. Repair guides, in-store services, or repairability guarantees are tangible signals that a brand takes product longevity seriously. And if data exists (number of items repaired, participation rates) it should be shared. Better still, if the user is involved, the communication becomes participative.
Second-hand and resale initiatives, when operated well, provide measurable impact. Whether run in-house or via a partner, they extend product life and reduce emissions. Here too, it’s not enough to claim the concept: impact should be evidenced, even via external benchmarks. A statement like “resale saves up to 90% CO₂ compared to new” is only valid if contextualised.
In short: structure enables substance. And substance, expressed with context and control, becomes your best protection, and your best message.
Because when the impact is real, it deserves to be seen.
Conclusion: When accountability starts from within
In a landscape where reputational risk is high and regulatory guidance is fragmented, brands no longer have to choose between silence and overstatement. The path forward lies elsewhere: in clarity, structure, and internal accountability.
Even in the absence of an EU-wide directive, the expectations remain clear. Consumers demand transparency. Regulators still act at national level. And watchdogs will continue to challenge misleading claims.
That makes internal rigour not just a best practice, but a form of self-regulation that protects both reputation and trust.
To escape the green communication trap, brands must shift the question from “what can we say?” to “what can we prove, explain, and stand by?”
That means:
- Auditing your actions before crafting your messages
- Separating regulatory minimums from voluntary efforts
- Documenting everything before publishing anything
- Aligning internal teams before reaching out to the public
- And building a decision framework for every claim you make
In short, don’t let fear dictate your message. Let structure and data support it.
Because when the work is real, the story deserves to be told clearly, and confidently.
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