Greenwashing Belgium: generic green claims on 21,689 small business sites

In November 2026, 4.3% of 21,689 Belgian small business websites used a generic environmental claim such as 'eco-friendly' or 'ecological' on their homepage or sustainability page. We read 200 of those sites by hand, and on 48.5% the claim stood bare: no label, no figure, no concrete measure within 300 characters. Across all sites that comes to 2.1%.

Since 27 September 2026 a business may make a generic environmental claim only if it can demonstrate recognised excellent environmental performance relevant to the claim, for example in line with the EU Ecolabel (Article VI.100, 29° of the Code of Economic Law). A claim with no specification on the same medium is such a generic claim and falls under that rule. We looked within 300 characters of the claim; an explanation further down the page or elsewhere on the site was not counted. Whether the company behind it can show that performance is something no crawler can see, so we count what the page says. The frame is the one from our October study of Belgian business websites, which lets you compare by sector and province.

Five practices the new rules touch

Belgium wrote Directive (EU) 2024/825 into its Code of Economic Law with the law of 22 July 2026, published in the Belgian Official Gazette on 4 August 2026 and in force since 27 September 2026. Article 14 of that law adds twelve practices to Article VI.100, the list of commercial practices that count as unfair in all circumstances. Four of them bear directly on what a small business puts on its website. A fifth rule, on claims about future performance, sits in Article VI.98.

The directive defines a generic environmental claim as one that is not part of a sustainability label and where 'the specification of the claim is not provided in clear and prominent terms on the same medium'. Recognised excellent environmental performance means performance in line with the EU Ecolabel, an officially recognised EN ISO 14024 type I ecolabel, or top performance under other Union law. Recital 9 lists examples: environmentally friendly, eco-friendly, green, nature's friend, ecological, climate friendly, carbon friendly, energy efficient, biodegradable, biobased.

Article 15 of the Belgian law adds a grace period for goods made, packed or placed on the market before 27 September 2026: the inspection powers of Article XV.2, § 1, do not apply to those cases until six months after entry into force. Services get no such grace period. The separate proposal for a Green Claims Directive has not been adopted; the European Parliament's file still awaits the Council's first-reading position. Our news piece on the EU ban walks through the rule point by point.

How often a claim word shows up

We found a generic claim on 677 homepages (3.1%). A further 255 sites had one on a linked sustainability page but not on the homepage, which brings the total to 932 sites, or 4.3% of the frame. A link to a sustainability page appeared on 896 homepages. We read 878 of those pages and found a claim word on 347.

Environmentally friendly and its relatives ('milieuvriendelijk', 'respectueux de l'environnement', 'eco-friendly') lead by a wide margin. 'Green' counts only when it describes the offer, as in 'green packaging', since the word is also a colour, a garden and a street name. A site can use more than one family, so the shares add up to more than 100.

French-language sites use a claim word a little more often than Dutch-language ones, 5.3% against 3.8%, and webshops more often than other sites, 5.9% against 4.0%. Neither gap reaches our 5-point threshold.

Half the claims come with nothing next to them

A claim word on a page says little about how the claim is made, so we read 200 random sites from the 932 by hand. On 97 the claim stood bare. On 53 it was specific or backed by something concrete, for example a percentage or the material. On 16 a label sat next to it, and only once was that the EU Ecolabel. The remaining 34 made no claim of their own: they quoted a customer, described a region or listed another brand's product.

Limited to the 166 sites that claimed something about their own offer or operations, 58.4% were bare. A specific claim escapes the rule on generic claims but stays subject to the general rules for any environmental claim. A label nearby is no safe harbour either: a home-made logo with no certification behind it is itself on the list (VI.100, 28°). If you want to turn a vague claim into a precise one, our page on SEO copywriting shows how plain, specific copy also tends to rank better than a vague adjective.

Business services, cars and construction lead

Three sectors stand out. Business services use a claim word on 8.5% of sites, automotive on 7.6% and construction on 7.4%, against 2.3% in hospitality and 1.1% in healthcare. Those gaps pass our threshold of 100 sites per group and 5 percentage points. Retail sits in between at 5.5%.

Many builders and garages sell something with an environmental angle, such as insulation, paint, heating or an electric car. That does not explain the gap, but it helps to read it. Builders rewriting their site can start with marketing for construction companies or a website for contractors; garages will find their sector notes on our garages page, installers on the page for solar installers.

The hand sample of 200 is too small to split the bare share by sector, so we do not.

No province really sets itself apart

By province, the share of sites with a claim word runs from 2.8% in West Flanders to 6.3% in Namur. The widest gap between two provinces with at least 100 sites is 3.5 percentage points, short of our threshold, so we single out no province.

Climate neutral: rare, and often a promise for later

Just 77 sites, 0.4% of the frame, say on their own behalf that they are climate neutral, carbon neutral or net zero, and 23 of them say so on the homepage. 39 speak in the present tense ('we are carbon neutral'); 38 only about the future ('net zero by 2030').

Of the 39 present-tense claims, 5 mention offsetting within 300 characters, such as planting trees or buying credits. Claiming that a product has a neutral, reduced or positive climate impact through offsetting has fallen under VI.100, 31° since 27 September. Whether a claim about the whole business falls under it, the text does not say in so many words. The other 34 mention no offsetting inside that window. A future claim without clear, verifiable commitments in a realistic implementation plan, regularly checked by an independent external expert, counts as a misleading practice (VI.98, 4°); whether such a plan stands behind the 38 future claims lies outside this measurement.

Sustainable and organic, counted apart

The Dutch word duurzaam, or its French and English counterparts durable and sustainable, appears on 2,408 homepages (11.1%), and on 28.4% in business services and 25.0% in construction. We keep it out of the claim count because it also means sturdy or long-lasting. The Belgian economy ministry does list it among vague terms that need explaining, so a business using it as an environmental promise should spell out why in the same sentence.

Bio, biologisch or organic appears on 865 homepages (4.0%). For food it points to organic farming rather than a general environmental promise, so it stays out of the headline. Energy efficient (61 sites) and green electricity (55 sites) were also kept apart, although recital 9 names energy efficient as a generic claim. Counting it in would raise the headline by at most 0.3 percentage points.

About pages add a few more

The headline covers the homepage and the sustainability page, yet claims also turn up on about pages. In a random sample of sites without a sustainability link we read 3,776 about pages; 125 of them (3.3%) carried a claim word while the homepage had none. So 2.1% is a floor, not a ceiling. If your about page needs a rewrite anyway, our about us page examples show how to describe what you actually do.

The limits of a page count

This study does not say any company is at fault. A bare claim falls under the new rule; whether the business can demonstrate recognised excellent environmental performance is not stated on the pages we looked at. OpenStreetMap overrepresents hospitality and retail. 1,703 sites that build their text with JavaScript were not read, and neither were product pages, PDFs or text inside images.

We measured the same frame for legal requirements on business websites, accessibility of webshops, how small business sites work on a phone and protection against email spoofing. What a new site costs is in our study of web design agency pricing.

Rewriting the green claims on your own site

Fixing a bare claim usually takes an hour of writing, not a new website. A workable order:

1. Find your own claim words. Open your homepage, about page and sustainability page and search for eco-friendly, green, ecological, climate neutral, carbon neutral and sustainable, in every language your site uses. Titles and the description Google shows count too; the SEO checker lists them for you.
2. Make each claim specific and make sure you can back it up, or drop it. Say what you do, with a figure or a material: water-based paint, an electric van, 80% recycled cardboard. A vague word with nothing next to it falls under the new rule.
3. Put the explanation next to the claim. In the same sentence or paragraph, not behind a link to a PDF.
4. Review your labels. Remove home-made logos and labels without certification. A label based on a certification scheme or set up by a public authority, such as the EU Ecolabel, is outside that ban; name it.
5. Climate neutral through offsetting? Take it down. Publish a future target only with a plan that someone independent checks.
6. Build it into your next rewrite. A website brief fixes in advance which claims you can back up, and our guide to copywriter rates shows what the writing costs. Planning a Black Friday campaign in Europe? Keep vague green promises out of that copy as well.

Rebuilding your site is the natural moment, because rewriting the copy is part of the job. Anyone who has a website built does well to agree up front which claims go in and what evidence comes with them. Want to go through it together? Book a call.