Circular Fashion

Spotting greenwashing in a sustainability report

A percentage with no baseline, a target year of 2050 and a graph without units are the three most reliable tells. New rules in Europe are about to make the worst claims illegal.

A printed sustainability report open at a page of charts beside a pair of glasses
Thriftfile Studio

Thriftfile may earn a commission when you buy through links on this page. We only link to pieces our editors would wear, and we tell you when something is not worth the money.

A sustainability report is written by the company it describes and is not usually audited to the standard of the financial statements. That does not make it useless. It makes it a document to read backwards: start with the scope, the baseline and the assurance statement, not with the page of numbers that went up.

The three most reliable tells are structural rather than rhetorical. A percentage reduction with no stated baseline year. A net zero target for 2050 with no interim target for 2030. A chart with no units on the vertical axis. Any one of those means the figures were chosen for their direction rather than their meaning.

The claims that commit to almost nothing

Common claims and what they actually assert

ClaimWhat it assertsWhat is missing
100 percent of our cotton is more sustainableA definition the company chose for itselfWhich standard, at which threshold, at which processing stage
Carbon neutral across our operationsOffsets or renewable energy certificates against measured operational emissionsSupply chain emissions, which are the large majority in clothing
Made with recycled materialsSome recycled content, at some percentageThe percentage, the feedstock, and whether it was textile waste
Working towards net zero by 2050An intentionInterim targets and committed capital
Conscious or responsible collectionA product lineA standard, a metric or a verification of any kind
We diverted 4,000 tonnes of wasteMaterial left a waste stream at some pointWhether it was reused, downcycled, stored, or shipped abroad
A collage featuring it items of
The scope note matters more than the headline figure. A reduction across company offices is a much smaller claim than one across the supply chain.Thriftfile Studio

What the law now requires, and what is coming

Europe has moved faster than anywhere else, and it is changing what a claim can say. The EU's directive on empowering consumers for the green transition bans generic environmental claims that can't be substantiated, and requires environmental claims to be backed by evidence. According to the European Commission, it has applied since September 27, 2026. Related proposals go further, requiring an accredited verifier for most green claims and targeting carbon neutral claims built on offsetting.

The United Kingdom has approached it through enforcement rather than legislation. The competition regulator has published a green claims code and investigated large online fashion retailers over vague words such as "responsible." In the United States, the FTC's Green Guides remain the main reference. They're specific in places; an unqualified "recyclable" claim, for example, needs recycling facilities available to at least 60 percent of consumers where the item is sold.

  • Generic words are the first casualty — Eco-friendly, green and sustainable are hard to substantiate for a garment, and enforcers in the United Kingdom and the European Union have said so. Expect specific claims with numbers attached instead.
  • Offsetting-based neutrality is going — A claim of climate neutrality resting on purchased offsets is the target of the incoming European rules. Brands are renaming those pages rather than retiring them.
  • Numbers need a home in a framework — Reports prepared against a recognized framework, with a scope statement and an assurance opinion, are harder to write selectively than a standalone brochure.
  • Enforcement is still behind the rules — Regulators have limited capacity, and a misleading claim usually has to be reported before anything happens. The rules make a complaint easier, not automatic.

Where the inconvenient numbers live

Growth in production volume is usually excluded from the environmental section and available in the financial one, where unit volumes are reported for investors. If tons produced rose 8 percent while emissions per garment fell 4 percent, total emissions still rose. That reconciliation is almost never printed, and it is the most useful sum a reader can do. Regulators do act on this: in June 2022 the Norwegian Consumer Authority told the Sustainable Apparel Coalition, H&M and Norrøna that consumer-facing use of Higg data was potentially misleading.

The same applies to targets measured per unit rather than in absolute terms. An intensity target is met by making more things, which is why absolute figures are the ones to look for and the ones most often absent. Where one does appear, check whether it covers the whole group or one brand.

Six garments whose paperwork survives a close read

Each item makes a claim that a specific standard or a published number can be checked against. Prices are shown only where we confirmed them on the brand or retailer page in Oct 2026.

Lofty Lo Organic JeansBest documentation

Nudie Jeans

Lofty Lo Organic Jeans

The repair figures are published annually as a count rather than a vague promise, which is the sort of number that is expensive to fake.

Organic cotton, published repair statistics

Check sold prices
Fleece Pullover, used

Patagonia

Fleece Pullover, used

Worn Wear publishes repair volume and resale activity. A claim from a company that has reported for a decade is easier to check.

A brand with a long public record

Check sold prices
Wool Coat

Filippa K

Wool Coat

A short, named supply chain is a stronger signal than a certificate, because the list can be compared against the same list a year later.

Traced wool with a published supplier list

Compare listings
V-10 Leather Trainer

Veja

V-10 Leather Trainer

Publishing which tannery supplied which leather is a hard claim to make loosely. It also shows how much of the shoe is not covered.

Leather traceability published by supplier

Compare listings
Ten Pack Socks

Organic Basics

Ten Pack Socks

A specific certification with a number you can look up beats any paragraph about sustainability. For socks, the certification is most of what there is.

GOTS certified cotton

Compare listings
Unbranded wool trousers

Secondhand

Unbranded wool trousers

The garment with no sustainability page is often the most honest purchase available, because buying it used displaces new production without any offsetting story attached.

No claims to verify at all

Compare listings
An image of a woman wearing
Thriftfile Studio

Reading one in twenty minutes

  1. 1

    Find the basis of preparation

    Usually an appendix. It names the framework, the scope and the exclusions. Everything else in the report is read in the light of it.

  2. 2

    Find the assurance statement

    If an independent accountant has checked the numbers, the level is stated. Limited assurance is narrower than a financial audit.

  3. 3

    Reconcile volume against emissions

    Take the production figure and the intensity figure and multiply. If absolute emissions rose, that is the story, whatever the intensity chart shows.

  4. 4

    Read the targets for interim years

    A 2050 target without a 2030 milestone is a statement of intent rather than a plan.

  5. 5

    Count the pages given to bad news

    A report that gives space to what went wrong is more trustworthy than one that finds a win in every chapter.

Hannah lovey in statement jeans
Per-unit improvements and rising production can both be true, which is why the reconciliation is the number to look for.Thriftfile Studio

Frequently asked

Is every sustainability report greenwashing?
No. Reports prepared against a recognized framework with an assurance statement are a serious attempt to disclose, and they are useful even when the numbers are poor. The problem is the marketing pages that sit alongside them under the same logo.
What is the single most useful number to look for?
Absolute emissions for the current year against the baseline year, alongside production volume for both. Two numbers, one division, and you can tell whether a company is cutting emissions or just emissions per garment.
Do recycled materials make a product sustainable?
They reduce the impact of the material, which is one input among several. Most of a garment footprint sits in fiber production and in how long the garment is worn, so a recycled polyester top worn five times is a worse outcome than a cotton shirt worn for a decade.
Will the new European rules change what I see in shops?
In European stores, yes: vague claims and offset-based neutrality claims will have to go, and evidence will have to exist before a claim is made. Brands selling elsewhere may keep different wording, which means the same company can run two standards of claim depending on the market.