A generic "eco-friendly" claim on a website can cost €100,000 in the Netherlands, €7.5 million in France, or 10% of global turnover in the UK — the same words, three orders of magnitude apart. Greenwashing penalties are set nationally, not at EU level, and the gap between jurisdictions is widening as the ECGT Directive enters enforcement on 27 September 2026.
This matrix compares the maximum fine, enforcement authority, and legal basis for greenwashing in the 10 largest EU markets plus the UK. Every figure is verified against a national statute, regulator publication, or actual 2024–2026 fine.
Summary — Who Fines Hardest?
Three jurisdictions currently set the upper bound of greenwashing risk:
- United Kingdom — up to 10% of global turnover under the Digital Markets, Competition and Consumers Act 2024 (DMCC), enforceable directly by the CMA since 6 April 2025.
- EU-wide floor — minimum 4% of annual turnover in the Member State concerned, or at least €2 million where turnover cannot be determined, for widespread infringements under Directive 2019/2161 (Omnibus Directive) and confirmed by ECGT transposition requirements.
- France — up to 4 years of imprisonment + €300,000 individual fine under the Loi Climat et Résilience Article L.229-68 for climate-neutrality claims lacking substantiation. The corporate fine is scaled by the company's average yearly expenditure on the misleading communication.
At the other end of the spectrum, Member States that have not yet transposed the ECGT still rely on general Unfair Commercial Practices Directive (Directive 2005/29) penalties — typically capped at €50,000–€100,000 per violation in national consumer law.
Country-by-Country Matrix
All amounts are maximum fines for a single severe greenwashing violation. Widespread cross-border infringements trigger the 4% / €2 million EU floor regardless of national ceilings (see section below).
| Country | Maximum fine | Enforcement authority | Legal basis |
|---|---|---|---|
| 🇬🇧 United Kingdom | 10% of global annual turnover | Competition and Markets Authority (CMA), Advertising Standards Authority (ASA) | Digital Markets, Competition and Consumers Act 2024 (in force 6 April 2025) |
| 🇫🇷 France | 80% of the cost of the misleading communication + up to €300,000 + 2 years' imprisonment (natural person); corporate fine in proportion to turnover | DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes) | Code de la consommation L.121-2 to L.121-7 + Loi Climat et Résilience (Art. L.229-68 for carbon neutrality) |
| 🇩🇪 Germany | Unlimited (proportionate) under UWG § 8–10; CMA-style fines expected through 2026 transposition of ECGT | Wettbewerbszentrale + competitors + consumer associations | Gesetz gegen den unlauteren Wettbewerb (UWG), amended 19 February 2026 to implement ECGT |
| 🇮🇹 Italy | Up to €10 million per violation (doubled for recidivism) | AGCM (Autorità Garante della Concorrenza e del Mercato) | Consumer Code (Codice del Consumo) + Legislative Decree of 9 March 2026 transposing ECGT |
| 🇳🇱 Netherlands | €900,000 or 1% of annual turnover per violation (whichever is higher); doubled for repeat | ACM (Autoriteit Consument & Markt) | Consumer Protection Enforcement Act (Wet handhaving consumentenbescherming) |
| 🇪🇸 Spain | Up to €1 million or 4% of turnover (serious infringements); €100,000 for minor | Ministry of Consumer Affairs + Autonomous Community consumer agencies + CNMC | General Consumer and User Defense Law (Real Decreto Legislativo 1/2007) |
| 🇧🇪 Belgium | Up to 10% of annual turnover for serious offenses; criminal sanctions possible | Economic Inspection (Inspection économique) of SPF Economie | Code of Economic Law (Code de droit économique), Books VI and XV |
| 🇮🇪 Ireland | €60,000 per charge (summary) / €5 million or 5% of turnover (indictable) | CCPC (Competition and Consumer Protection Commission) | Consumer Protection Act 2007 (as amended) |
| 🇵🇱 Poland | Up to 10% of annual turnover | UOKiK (Urząd Ochrony Konkurencji i Konsumentów) | Act of 16 February 2007 on Competition and Consumer Protection |
| 🇸🇪 Sweden | Market disruption fine up to 10 million SEK (~€900,000); for serious infringements up to 4% of turnover under new EU minimum | Konsumentverket / Consumer Ombudsman | Marknadsföringslagen (Marketing Act 2008:486) |
| 🇩🇰 Denmark | Fines proportionate; for ECGT-scope widespread infringements, minimum 4% of turnover | Forbrugerombudsmanden (Consumer Ombudsman) | Markedsføringsloven (Marketing Practices Act) |
Sources: national statutes cited plus: UK CMA press release on DMCC Act entry into force (April 2025), Latham & Watkins — EU State of Play (22 October 2025), and Charles Russell Speechlys — Anti-greenwashing risk landscape (April 2026).
Recent Fines in Context (2024–2026)
| Country | Company | Year | Amount | Violation |
|---|---|---|---|---|
| France 🇫🇷 | TotalEnergies | 2025 | €7.5 million | Misleading "energy transition" claims for natural gas (DGCCRF) |
| France 🇫🇷 | Shein | 2025 | €40 million | Unverifiable 25% emission-reduction claim + misleading pricing (DGCCRF) |
| France 🇫🇷 | Decathlon | 2025 | €2.3 million | Self-created "Eco Design" product scoring (DGCCRF) |
| Italy 🇮🇹 | Ryanair | 2025 | €5 million | "Lowest CO₂ emissions" claim without methodology (AGCM) |
| Italy 🇮🇹 | Shein | 2025 | ~€1.16 million | Environmental marketing practices investigation (AGCM) |
| Netherlands 🇳🇱 | H&M | 2025 | €3.6 million | Self-certified "Conscious Collection" (ACM) |
| Netherlands 🇳🇱 | KLM | 2025 | Court-ordered cease + corrective advertising | "Fly Responsibly" / SAF misrepresentation (Amsterdam District Court) |
| Netherlands 🇳🇱 | Shell | 2025 | Court-ordered ban extension | "Carbon neutral driving" campaign (Amsterdam District Court) |
| Germany 🇩🇪 | Volkswagen | 2026 | €4.2 million | "Zero emissions" on ID. electric line without scope qualification |
| Finland 🇫🇮 | Neste | 2025 | €1.8 million | "Up to 90%" emissions reduction claim on renewable diesel (KKV) |
| Ireland 🇮🇪 | Primark | 2025 | €900,000 | "Primark Cares" whole-product halo label (CCPC) |
The Shein France fine is the largest single greenwashing penalty to date in the EU. The French regulator combined unverifiable environmental claims with misleading pricing practices — a composite-infringement pattern that multiplied the statutory maximum.
Detail and case files: Top 10 Greenwashing Fines 2025–2026.
The 4% Widespread-Infringement Floor
Whatever the national ceiling, Directive 2019/2161 (Omnibus Directive), amending the Unfair Commercial Practices Directive 2005/29, requires every Member State to impose fines of at least 4% of annual turnover in the country concerned — or at least €2 million where turnover cannot be determined — for "widespread infringements" or "widespread infringements with a Union dimension."
A greenwashing campaign that appears simultaneously in three or more Member States meets the "Union dimension" threshold under the CPC Regulation 2017/2394. In that case, coordinated enforcement by the CPC network can apply the 4% floor regardless of lower national caps.
Illustrative math: a company with €500 million annual EU-wide revenue making a single misleading green claim visible across Germany, France, and the Netherlands could face a minimum €20 million fine under the coordinated procedure — even if each national authority's standalone cap is lower. The Cambridge University Press analysis by MacLennan (2025) confirms this floor is now the binding constraint for large multinationals.
What Compliance Teams Should Do
- Map your exposure country-by-country. For each EU market where you publish environmental claims, record the enforcement authority, the penalty ceiling, and the transposition status of the ECGT.
- Price widespread-infringement risk at 4% of EU turnover. That is your realistic ceiling for a single coordinated enforcement action, not the lowest national cap.
- Audit every page before 27 September 2026. Use our free scanner to flag ECGT-banned terms on any URL in under 60 seconds. Results are benchmarked against the EU's 28 banned and restricted term list.
- Align copy to the strictest jurisdiction. Language that clears UK DMCC Act + French DGCCRF scrutiny will pass everywhere else.
Calculate Your Exposure
The free scanner flags every banned term, shows which country's rules each infringes, and outputs a PDF compliance report.
Free Greenwashing ScanFrequently Asked Questions
Which country has the highest greenwashing fines?
The United Kingdom has the highest ceiling: 10% of global annual turnover under the Digital Markets, Competition and Consumers Act 2024, enforceable by the CMA since 6 April 2025. France and Italy offer the highest statutory fines in the EU (€10M Italian AGCM; proportional fines + criminal sanctions in France under Loi Climat).
What is the EU-wide minimum penalty?
For widespread infringements affecting multiple Member States, the minimum fine is 4% of annual turnover in the country concerned, or at least €2 million where turnover cannot be determined. Set by Directive 2019/2161 (Omnibus Directive) amending the UCPD.
What was the largest greenwashing fine to date?
Shein's €40 million fine by France's DGCCRF in July 2025 is the largest single greenwashing-related penalty in the EU so far. It combined unverifiable environmental claims (25% emission reduction) with misleading pricing practices.
Can I be fined in multiple countries for the same claim?
Yes. Under the CPC Regulation 2017/2394, coordinated enforcement across multiple Member States can result in parallel or consolidated penalties. The CPC network routinely coordinates responses to pan-EU greenwashing campaigns.
Do criminal sanctions apply?
In France, Loi Climat et Résilience Article L.229-68 introduces up to 2 years' imprisonment for individuals (up to 4 years with aggravating factors) for false climate-neutrality claims. Belgium and Germany also allow criminal sanctions under their consumer law for serious, repeated violations.
Bottom Line
Greenwashing penalties in 2026 are no longer theoretical or symbolic. The UK's 10% global-turnover cap and the EU's 4% widespread-infringement floor together define a new risk envelope. The only defensible strategy is to align marketing copy to the strictest national transposition, audit every page before 27 September 2026, and price legal exposure at 4% of EU revenue — not at the lowest cap in any single country. Start with a free scan of your website today.