Last updated: October 15, 2026. Next update: January 2027.
California has now collected $5.1 million from seven plastic bag makers over "recyclable" claims. That's the largest running total on this page. Recycling claims are still where most US enforcement lands.
Net-zero targets are the fastest-growing new category. In late 2025, JBS paid $1.1 million and Tyson agreed to drop "net zero" and "climate-smart" claims unless an expert verifies them.
What this tracker logs: government enforcement actions, court rulings and major settlements over environmental marketing claims. Coverage: US federal, state and city actions, plus EU, UK, French, German and Australian actions that set a precedent for brands selling there. Method: each entry is checked against a primary source (press release, court record or regulator ruling) or at least one law-firm analysis of it. Entries are dated by ruling, settlement or filing date. Update cadence: quarterly. New cases are added at the top of the log.
What the 2025 to 2026 Cases Show
- Recycling claims draw the most US enforcement. California, Arizona and Philadelphia all went after "recyclable" labels on plastic film and bags.
- Net-zero targets now need a plan behind them. Regulators didn't argue the targets were lies. They argued the companies had no realistic path to them.
- Offset-based "carbon neutral" claims split by jurisdiction. The same Apple Watch claim lost in Germany and survived in a US federal court.
- Courts reward specific, testable claims and punish vague ones. A hangtag with a percentage on it could be tested and challenged. Vague website copy got dismissed.
- The EU just raised the bar. Since September 27, 2026, offset-based neutrality claims on products are banned for EU consumers.
The Log
| Date | Company | Claim | Who acted | Outcome |
|---|---|---|---|---|
| Jul 14, 2026 | California's SB 343 (truth-in-recycling law) | Limits on "chasing arrows" and recyclability claims | US District Court, S.D. California, in a suit by a food and packaging trade coalition | Preliminary injunction blocks the state from enforcing SB 343 against any business while the case proceeds |
| Feb 23, 2026 | Reynolds Consumer Products (Hefty) | "Recycling" bags made of film most facilities reject | Arizona Attorney General | $212,000 settlement |
| Feb 20, 2026 | Apple | "Carbon neutral" Apple Watch models, based on offsets | US District Court, N.D. California (Dib v. Apple) | Dismissed. Plaintiffs didn't plausibly allege the claim was false. They declined to amend. |
| Feb 2026 | H&M | Hangtags claiming 55% and 56% recycled polyester | Federal court in Missouri (Sally v. H&M) | Hangtag claims allowed to proceed. Website-based claims dismissed. |
| Jan 16, 2026 | Novolex, Inteplast, Mettler Packaging | "Recyclable" plastic bags with chasing arrows | California Attorney General | $3.35 million combined. With four earlier settlements, seven producers have paid $5,103,000. |
| Dec 3, 2025 | Nike, Lacoste, Superdry | "Sustainable" as a standalone claim | UK Advertising Standards Authority | Ads banned |
| Nov 2025 | Tyson Foods | "Net zero by 2050" and "climate-smart beef" | Environmental Working Group, DC Superior Court | Settled. For five years, Tyson can't make these claims unless a mutually agreed expert verifies them. |
| Nov 5, 2025 | JBS USA | "Net zero by 2040" | New York Attorney General | $1.1 million. Must call the target a "goal," describe the specific steps it's taking and review its claims each year for three years. |
| Oct 2025 | Four plastic bag manufacturers | Chasing arrows on bags with no recycling pathway | California Attorney General | $1.75 million combined |
| Oct 23, 2025 | TotalEnergies | "Carbon neutrality by 2050" ambition on its French consumer energy site | Paris Judicial Court, in a suit by NGOs | 3 of 44 challenged statements found misleading. Ordered to remove the 2050 statement. Corporate and rebranding claims dismissed. |
| Sept 2025 | SC Johnson, Bimbo Bakeries | "Recyclable" film bags and bread wraps | City of Philadelphia | Lawsuit filed |
| Aug 26, 2025 | Apple | "CO2-neutral" Apple Watch | Frankfurt Regional Court, in a suit by Deutsche Umwelthilfe | Claim banned. The offset project's land leases weren't secured past 2029. |
| Jul 2025 | Shein | Unsupported claim about greenhouse gas reductions, plus misleading discounts | France's DGCCRF and prosecutors | €40 million settlement fine |
| May 2025 | Coca-Cola | "100% recycled plastic bottle" that excluded cap and label | European Commission and EU consumer authorities | Required to state the exclusion |
| Jun 2024 | Active Super | Fund marketed as excluding coal, Russian oil and gas, and tobacco | Australian Securities and Investments Commission | Federal court found against the fund |
The Patterns, Case by Case
Recycling claims: most of the US volume
The bag and film cases all follow one logic. The material might be recyclable somewhere. It isn't accepted by the facilities where the product is sold. California's SB 270 cases rest on that gap, and so do Arizona's Hefty settlement and Philadelphia's suit.
One caveat for 2026. A federal judge blocked California's newer SB 343 law in July, on vagueness and First Amendment grounds. That ruling is preliminary. It doesn't touch the SB 270 bag settlements, and it doesn't stop private lawsuits under other laws. Don't read it as an all-clear on recyclability claims.
Net-zero targets: a goal needs a path
JBS and Tyson weren't punished for missing a target. They were challenged for announcing targets with no realistic plan, while production kept growing. The fixes were the same in both cases. Call it a goal. Say what you're actually doing. Get the claim verified.
Carbon neutral: same claim, opposite outcomes
Apple's Apple Watch claim is the clearest split on this page. A German court banned it in August 2025 because the forestry offsets behind it weren't secured long term. A US federal court dismissed a challenge to the same claim in February 2026 because the plaintiffs couldn't show the offsets were miscounted.
Since September 27, 2026, the question is moot for EU consumers. The Empowering Consumers for the Green Transition Directive bans product claims of neutral, reduced or positive climate impact that rely on offsets.
Specific claims are easier to test, in both directions
H&M's hangtags named a percentage, so a shopper could test them. That's why those claims survived dismissal. The UK's Nike, Lacoste and Superdry rulings show the reverse. "Sustainable" with no qualifier promised more than the real data behind it.
The lesson isn't to avoid specifics. It's to make sure every specific number holds up. For why regulators stopped asking about intent, see what greenwashing actually is.
What to Watch Next Quarter
- SB 343 litigation. Whether the injunction holds through trial. The original compliance date was October 4, 2026.
- ECGT enforcement. The first EU actions under the new rules on generic claims and offset-based neutrality.
- FTC Green Guides. Still the 2012 version. The review opened in 2022 hasn't produced revised Guides yet.
- Philadelphia v. SC Johnson and Bimbo. The first major city-led recycling claim case still moving.
Salish Sea Consulting checks sustainability claims against the evidence behind them before they ship. If a claim on your packaging or site looks like one of the cases above, let's talk.
Frequently Asked Questions
What are recent examples of greenwashing enforcement?
Recent cases include California's $5.1 million in settlements with seven plastic bag makers, New York's $1.1 million settlement with JBS over a net-zero pledge, Tyson's agreement to drop "climate-smart beef" claims and a German court's ban on Apple's "CO2-neutral" watch claim.
Can companies still say "carbon neutral"?
In the EU, not for products if the claim relies on offsets. That ban took effect September 27, 2026. In the US, it depends on substantiation. A federal court dismissed a challenge to Apple's claim in 2026 because the plaintiffs couldn't show the offsets were miscounted.
Is greenwashing illegal in the US?
Misleading environmental claims can violate Section 5 of the FTC Act and state consumer-protection laws. The FTC's Green Guides explain how it judges claims. State attorneys general and cities have brought most recent cases.
How often is this tracker updated?
Every quarter. Each update adds new rulings and settlements to the top of the log and revises the patterns section if something changes.