Poland: UOKiK strikes again against greenwashing

On Monday, 19 January, the President of UOKiK announced that charges had been brought against Bolt, Tchibo and Zara for so-called greenwashing. 

What does UOKiK accuse the companies of?

Misleading consumers with so-called "green slogans". The President of UOKiK points out that companies' environmental claims must be clear and verifiable with data available to consumers.

Bolt - more "eco" than in reality

UOKiK is analysing communications about "zero-emission vehicles" and the type of energy used in Bolt's journeys and deliveries.

According to the regulator, Bolt offers a certain standard to consumers which in reality does not apply to its entire activity, but only to part of it, specifically the "Project Zero". Most of the services offered by Bolt are still provided by combustion engine vehicles.

For example, Bolt vehicles’ "zero emissions" or "zero carbon" status applies only to the driving stage, not to the entire life cycle of the vehicle. Thus, general communication about "zero emissions" may be misleading to consumers.

The slogan "100% renewable energy" for offices, warehouses and charging stations may also be misleading. According to UOKiK, this is probably based on EAC certificates, which compensate for the energy consumed. Consumers may not be aware of how this mechanism works and that it does not apply to the direct purchase of energy from renewable sources.

Tchibo – when "eco" is just a label

UOKiK also draws attention to online business. In the Tchibo online store and app, the manufacturer uses a green leaf symbol and labels such as "sustainable" and "eco". However, the criteria for awarding these labels have raised serious doubts on the part of UOKiK. 

Such labels have been found, among others, on products made mostly of synthetic materials, such as polyester, or those that contain only 10% recycled materials.

UOKiK also took a closer look at Cafissimo capsules, which are presented to consumers as "recyclable", "made exclusively from recyclable materials" and "returning to the material cycle". In practice, this return to the material cycle only applies to Germany and Austria. However, Tchibo only provides this disclaimer in English and German. Thus, the average consumer in Poland who buys Cafissimo capsules online does not receive complete and adequate information about their recyclability. 

Zara – eco-promises without data

UOKiK also draws attention to the building of an eco-friendly brand image online. In this regard, it examined the "Join life" section, which Zara uses in its online store and app to emphasise how important "sustainable development" is to it. However, UOKiK claims that apart from declarations about responsible business practices, there is no specific data in this section about the brand's actual environmental activities.

According to UOKIK, such communication may suggest to customers that all stores apply the policy presented, while some of the slogans only apply to individual stores. An example given is the slogan "zero waste in our own facilities", which in Poland could apply to as little as 1 in 40 stores.

At the same time, slogans such as "100% energy from renewable sources in our installations", "Zero waste" and "Zero net emissions" are not accompanied by any explanations or descriptions of the scale of the activities.

The allegations concern not only marketing communications, but also product descriptions. Consumers are presented with the percentage share of raw material and the abbreviation of the certificate. Such information on the product card may suggest that the entire product meets a specific standard, and not just the certified raw material contained in the material. Furthermore, it is unclear what the certificate presented means and what requirements the product or material had to meet in order to obtain it. 

What awaits businesses?

Businesses face penalties of up to 10% of their turnover for engaging in unfair market practices. These are not the first actions taken by UOKiK in this area. Last year, the regulator accused companies such as Allegro, DHL, DPD and InPost of greenwashing. 

These actions by UOKiK suggest that in the coming months, businesses from various sectors should prepare for increased interest from the regulator in greenwashing.

To ensure compliance with the regulations, it is worth checking the descriptions and labelling of your products and marketing communications today.

• Are graphic and verbal labels used, such as "eco" and "sustainable", and are the certificates presented understandable to consumers and not misleading?
• Are the messages too general, e.g. do they refer to all areas of the company's activity instead of selected ones?
• Are marketing messages about environmental issues supported by data and can consumers easily verify their accuracy, e.g. does the term "sustainable" refer to the production method or the raw materials used?
• Is the information on recycling consistent with the rules in force in a given country, e.g. are there any restrictions on recycling that consumers should be informed about?
• Is the communication about sustainability and ecology consistent across all communication channels?

Ecology at the forefront in the coming year – new rules of the game

UOKiK seems to be following the trends in the European Union. It is worth remembering that by 27 March 2026, Member States should adopt and publish the provisions necessary to implement Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU with regard to empowering consumers in the green transition through better protection against unfair practices and better information.

The Directive clarifies the list of unfair commercial practices by extending it to include further cases of misleading conduct, including making environmental claims without clear, objective and publicly available data that consumers can verify, advertising consumer benefits that are irrelevant and do not result from any feature of the product or the trader's activity. In addition, misleading claims will also apply to environmental or social characteristics, aspects related to the circular economy, such as durability, repairability or recyclability.