Greenwashing Is Now a Matter of Proof, Not Morality

An ordinary billboard for a household cleaning product. A green package, two words printed on it: 'eco-friendly.'

As of 1 August, that is no longer just an advertising slogan. It is a legal claim. And in Türkiye, every claim of this kind now has to travel with an auditable file behind it.

The Ministry of Trade's amendment to the Regulation on Commercial Advertising and Unfair Commercial Practices, published in the Official Gazette on 1 July 2026, entered into force on 1 August after a one-month compliance period. At first glance the change looks technical. In practice, it is significant enough to reshape how companies communicate about the environment altogether.

What has changed is not the duty to prove a claim — advertisers were already required to substantiate what they said, and the Advertising Board had for years sanctioned unsubstantiated environmental statements. A 2022 Guideline on Environmental Claims had already laid out important principles in this area. What is new is the standard of proof itself. The amendment elevates those guideline-level principles into binding regulation.

One of the most important innovations is that the concept of an 'environmental claim' is, for the first time, defined in detail within the regulatory text itself. Under the new definition, any statement or visual asserting that a good or service delivers an environmental benefit, or reduces a negative environmental impact — whether in its components, production, marketing, use, or disposal — now counts as an environmental claim. This definition carries an important shift in mindset. Attention no longer falls only on the product itself, but on its entire life cycle. Packaging made from recycled material is no longer enough to render invisible the environmental impact of the rest of the production chain.

Four core obligations now apply. General terms cannot be used without explanation: broad concepts like 'eco-friendly,' 'green,' or 'sustainable' must be grounded in something specific. The claim must clearly indicate which part of the product, or which stage of its life cycle, it concerns. The measurement or assessment methodology used must be disclosed, either in the advertisement itself or on a linked web page. And certifications or verifications must be backed by documentation from authorized bodies, universities, or accredited and independent organizations.

Another notable change concerns the definition of deception. The regulation now explicitly emphasizes not only 'deceptive' but also 'misleading' practices. This distinction matters, because greenwashing rarely relies on outright lies. More often, it is built from true statements stripped of context. Highlighting only a product's favorable attribute while rendering the whole picture invisible can be more effective — and more dangerous — than stating something outright false.

Brussels is working through a similar problem, on a different timeline. The Green Claims Directive, proposed in March 2023, aimed to require companies to substantiate environmental claims using shared methodologies and, in many cases, undergo independent verification. But the process has moved far more slowly than expected. Political consensus broke down in the summer of 2025, trilogue negotiations were suspended, and the European Commission has signaled it may withdraw the proposal, though the file has not formally been pulled and remains on the EU's pending legislative agenda.

A separate EU instrument has already taken effect, however. The Empowering Consumers for the Green Transition Directive, adopted in February 2024 and amending the bloc's unfair commercial practices law, requires member states to transpose new rules into domestic law by 27 September 2026. Among other things, it bans unsubstantiated generic environmental claims and terms like 'climate neutral' or 'carbon neutral' when based solely on carbon offsetting, and it sets maximum fines for widespread, cross-border infringements at no less than 4 percent of a company's annual turnover in the country concerned.

So while the EU continues negotiating a more comprehensive verification framework, Türkiye has already put into force a narrower — but operative — proof regime in advertising law.

The new rule is also likely to produce a second, less obvious effect. A duty to prove naturally raises the cost of lying. But that same cost also rises for companies that want to tell the truth. Life-cycle analyses, third-party verifications, and independent certification processes can represent a significant expense, particularly for small and medium-sized enterprises. In such an environment, the safest communication strategy sometimes becomes saying nothing at all.

The international literature has a term for this: greenhushing. Companies, fearing criticism or sanction, choose not to talk about even their genuine environmental achievements. The paradox of this new era may therefore be that as greenwashing declines, green silence rises. Both carry real costs, just different ones.

The new rules apply to consumer-facing commercial advertising. But the same standard of proof is not yet applied, in identical form, to companies' integrated reports, sustainability strategies, or long-term net-zero commitments — those remain subject to different legal frameworks and reporting regimes. So today, a company must supply detailed evidence for the phrase 'eco-friendly' printed on its packaging, while its long-term climate pledges are still assessed under a different, and looser, logic of oversight. It would not be surprising if these two worlds move closer together in the coming years.

Türkiye will host COP31 in Antalya from 9 to 20 November. Companies, sponsors, and brands arriving from around the world will bring with them not only their climate policies but also the environmental claims printed on their materials. That November, Antalya will likely become the site of the densest concentration of environmental claims this country has ever seen in one place — sponsor boards, airline offset messaging, neutrality statements, in dozens of languages at once.

Türkiye's real card at that summit is not what happens at the negotiating table — it is what is already practiced at home. Host countries are read not by what they say from the podium, but by the enforceability of their own rules. On that score, the host country has taken a meaningful step toward verifying environmental claims. The point is no longer simply to say that you protect the environment. It is to be able to prove it.

That is where the next round of competition will begin. Companies will no longer compete to appear the greenest — they will compete to be the ones who can most solidly prove what they say. In environmental communication, the new currency will not be promise. It will be verifiable evidence.