Everything you need to know about greenwashing

Greenwashing is a real and growing problem in the European HVAC and refrigeration (HVACR) industry. It is generally understood as a marketing technique that may enhance a product’s green credentials to make it look more energy efficient and environmentally friendly than it really is. Greenwashing can undermine trust, may distort procurement decisions, can increase operational risk, and may slow efforts to genuinely decarbonise buildings and processes.

With sustainability no longer a ‘nice to have’ but a key feature of product specification, this article will explore why greenwashing matters, how it works, the rise of greenwashing schemes, their potential impact on all industry actors, initiatives to tackle the practice, and provide practical advice on how to avoid greenwashed products.

Why greenwashing matters

Greenwashing has become part of everyday life. Back in 2021, The European Commission and national consumer authorities released the results of a screening of websites (“sweep”), an exercise carried out each year to identify breaches of EU consumer law in online markets. For the first time, the analysis focused on greenwashing. The sweep found that in 42% of cases, environmental claims were exaggerated, false or deceptive and could potentially qualify as unfair commercial practices under European Union (EU) rules.

While the screening covered general consumer goods, it demonstrates how widespread the practice of greenwashing may be, and how it has potentially penetrated many aspects of daily life.

Marketing practices in the HVACR sector can, in some cases, present similar challenges. If manufacturers or suppliers overstate capacity and efficiency, underplay refrigerant leakage risks, or promote “eco” credentials without independent proof, buyers may pick products that underperform. Independent, comparable data is therefore widely recognised as essential to avoid costly mistakes.

How greenwashing works

As environmental responsibility becomes a stronger selling point, companies naturally want to market the green credentials of their products. Where environmental claims are accurate, specific, and supported by evidence, this is a key method to help buyers choose sustainable products to decarbonise buildings and processes.

However, market practices are not always consistent, and some companies may overstate or exaggerate the environmental benefits of products, while others may rely on poorly substantiated green claims.

Greenwashing tactics in the HVACR sector may include:

• Using “up to” performance figures taken from ideal lab conditions, or highlighting a best-case test point
• Overemphasising one green feature, e.g. promoting a low-GWP refrigerant while not fully contextualising energy performance
• Comparing a new product to an outdated or non-representative benchmark to make the gain look bigger
• Using vague terms like “eco-friendly,” “planet-positive,” or “green-certified” without reference to measurable, verified criteria
• Displaying unverified or self-awarded “eco” labels and logos that lack independent oversight.

These practices can mislead buyers, may erode trust, and can contribute to an uneven playing field where genuinely efficient, sustainable technologies struggle to stand out.

The rise of environmental labels and logos

Greenwashing schemes in the form of unverified or self-awarded labels and logos have entered every aspect of the European market, from general consumer goods to HVACR products. According to figures from the European Commission, when it comes to labels on the environmental performance of products (both goods and services) and companies:

• 53% of green claims give vague, misleading or unfounded information
• 40% of claims have no supporting evidence
• Half of all green labels offer weak or non-existent verification
• There are 230 sustainability labels and 100 green energy labels in the EU, with widely varying levels of transparency.

Where entry criteria are limited, participants in some schemes may obtain an “eco-friendly” logo on the basis of limited verification. This can make it harder for buyers to distinguish robust eco labels - supported by laboratory testing, data analysis, audits and checks - from schemes that offer limited or no verification. As a result, buyers may be influenced by “green” messaging and place reliance on labels that do not necessarily provide the same level of assurance.

However, for the informed, there are ways to spot a greenwashing scheme. Decision makers should look out for:

• Entry criteria that is not transparent e.g. technical information on the award process, or what constitutes a pass or fail is not publicly published or available
• No requirement for controls such as laboratory tests or audits
• Self-declaration, meaning that the information provided is not verified by an impartial third-party.
• Independent certification and transparent testing are vital tools in combating greenwashing and ensuring accountability across the supply chain.

Impact of greenwashing

Greenwashing has the potential to pose a significant threat to genuine sustainability progress in the HVACR industry. Overstated performance figures, unverified claims about refrigerant benefits, or selective reporting of test points can lead to:

Poor procurement decisions: Specifiers relying on overstated manufacturer data may select systems that fail to meet loads or regulatory requirements, causing redesigns, callbacks, or costly retrofits. Inflated claims reduce the reliability of decision-making and increase buyer risk.

Higher OPEX and degraded comfort: End users may experience higher energy bills and performance shortfalls when real-world efficiency is worse than claimed. This leads to mounting operational costs, higher CO₂ emissions and potential compliance failures.

Erosion of trust and market distortion: Installers and manufacturers that follow transparent practices may be disadvantaged when misleading claims confuse buyers; over time, this can reduce confidence in legitimate claims and certifications making it more difficult for genuinely low-GWP or high-efficiency technologies to clearly differentiate themselves in the market.

Initiatives tackling greenwashing

The EU has strengthened product rules via the Ecodesign for Sustainable Products Regulation (ESPR) to improve comparability and lifecycle performance of products, but at the time of publication, there is little in EU legislation that harmonises action against greenwashing practices across all sectors.

Proposed plans to systematically tackle Greenwashing via the Green Claims Directive were withdrawn in June 2025. However, regulatory developments continue to evolve. The Empowering Consumers Directive (EmpCo Directive), which must be implemented by EU Member States by 27 March 2026 and will apply from 27 September 2026, tightens the requirements for “green advertising”.

The new rules will apply to all HVAC and refrigeration products as the EmpCo Directive is not product specific. Instead, it amends the Unfair Commercial Practices Directive (UCPD), which covers all business-to-consumer marketing practices in the EU single market. That means any company selling or promoting HVAC or refrigeration systems to end-users, housing providers, or in certain cases B2B contexts that affect consumers, may fall within its scope.

From 27 September 2026 words like “energy efficient,” “climate neutral,” “eco-friendly,” or “low-carbon refrigerant” will only be permitted where claims are specific, verifiable, and supported by appropriate evidence.

Only recognised, third-party, or legally established energy labels can be used. Any self-declared “green” labels created by manufacturers without proper independent verification are expected to no longer be acceptable under the Directive.

Claims about lifecycle performance (e.g. “saves 20% energy over 10 years,” “low GWP refrigerant with minimal climate impact”) must be backed by robust, transparent and verifiable evidence.

This means that manufacturers will need to review and, where necessary, align product brochures, websites, catalogues, and sales materials with EmpCo standards. Installers, distributors, and specifiers who pass on claims from manufacturers should also ensure they are relying on compliant, substantiated statements, otherwise, they may face increased risk when forwarding misleading claims.

The aim is to ensure end-users benefit from clearer, more reliable environmental information, reducing the risk of investing in equipment that doesn’t perform as sustainably as advertised. However, the effectiveness of the new framework will depend on implementation and enforcement at national level, and market vigilance will remain important.

What can be done to combat greenwashing now?

The market already has a response to greenwashing: independently validated data. Industry actors can reduce risk by relying on products that have had their energy efficiency and performance verified by an independent, impartial, expert third-party.

Certifiers such as Eurovent Certification put products through a fair but rigorous process including laboratory tests, factory audits, software audits/checks, and evaluation of all submitted data (including marketing materials), with the objective of verifying consistency and accuracy. Certification under programmes such as Eurovent Certified Performance are designed to support specifiers and installers by providing comparable, impartial and validated data. Additionally, Eurovent certified products enter a surveillance process intended to help ensure data and manufacturer claims remain accurate and to reduce the risk of greenwashing.

Decision makers can protect against greenwashing by:

1. Asking for third-party certification via recognised schemes such as Eurovent Certified Performance.
2. Requesting full test reports and Product Performance Rating (PPR). Where products are not certified, decision makers should avoid relying solely on summary tables or single-point “up to” figures, and should verify test laboratory, test standard and test conditions. If the product is certified you can find, compare and download PPRs on the Eurovent Certification website via the Certified Product Directory.
3. Comparing seasonal metrics, not just peak numbers - e.g., SCOP/SEER rather than a single COP at a mild test point.
4. Checking EPREL / public product databases for appliances sold in the EU (energy label registrations). If a product isn’t listed, claims should be assessed with caution.
5. Watching for vague claims (“eco”, “green”, “planet-friendly”) that are not supported by measurable, verifiable metrics and references.
6. Demanding lifecycle info such as refrigerant GWP, leakage rate expectations, service intervals and expected lifetime.
7. Checking whether test units came from production line stock and not special pre-production samples. Eurovent Certified products always come from the production line, factory stock or point of sale, ensuring the product tested is the same as those leaving the production line. Also check whether software/selection tools are certified.

These steps reduce risk of selecting under-performing equipment and make procurement defensible.

Conclusion

Greenwashing represents a real and growing challenge to the HVACR sector. While regulators are strengthening rules and enforcement mechanisms, specifiers, installers and end users also have a role to play. Decision makers should seek independent certification, insist on transparent and complete performance data and rely on harmonised metrics and verified databases when comparing equipment. The combination of regulation + market discipline + third-party verification can play a significant role in reducing risks and supporting informed, defensible procurement decisions, that protect the climate.

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