'So we'll just stop saying anything at all.' This describes an understandable concern when companies navigate the new rules. The logic behind it is understandable: new rules, warning-letter risk, uncertainty about which terms are safe, complex evidentiary requirements. Why keep talking about sustainability at all? The answer is that silence does not actually solve the underlying problem.
Greenhushing reduces communication, not responsibility
Companies that are implementing genuine sustainability measures will typically keep collecting data, pursuing targets, changing supply chains, or reducing energy use regardless of what marketing says publicly. These activities do not disappear just because marketing stops mentioning them. At the same time, customers, employees, business partners, and other stakeholders lose access to information that may be relevant to their own decisions. The goal, therefore, should not be less sustainability communication, but better sustainability communication.
Our data points in exactly that direction
As of 22 September 2026, VERDAI had captured 34,529 environmental claims across 74,371 URLs from real corporate communications — though not every captured claim has necessarily gone through a full risk assessment. Among 5,235 documented decisions in our working dataset, a notably clear pattern emerges: 55.8 percent of claims were reworded, 36.9 percent were accepted as-is, 5.1 percent were excluded, and only 2.2 percent were removed outright. This is not a representative survey of the wider economy — the figures come from VERDAI's real operational dataset, with a comparatively high share from tourism and destination management, and they do not prove, on their own, that greenhushing is not happening elsewhere. Still, the pattern is interesting: most problematic statements, in this dataset, did not need to disappear. They needed to become more precise.
From image claim to factual information
Greenhushing tends to emerge where sustainability communication has long consisted mainly of image-driven language: 'We live sustainability.' 'We are green.' 'Travel in an environmentally friendly way.' When such claims are dropped, a communicative gap can open up initially. That gap can be filled instead with concrete measures, measurable results, clearly defined targets, certifications, comparative figures, methodologies, and clearly stated limitations.
Uncertainty can be communicated too
Companies do not need to claim perfection — quite the opposite. A sentence such as, for illustration: 'Our largest emissions currently arise in [a named area]. We do not yet have a complete reduction solution for this' can be more credible than ten pages of polished communication. Transparency does not mean publishing only positive figures. It means bringing statements and reality into alignment.
Perhaps the most important shift
Sustainability communication in the coming years will likely rely less on big labels and more on verifiable, specific pieces of information. That is not a weakening of communication — it can be a genuine improvement in quality. Instead of asking 'what are we even still allowed to say?', companies should be asking 'what can we say concretely and defensibly?' That distinction is the difference between greenhushing and credible communication.
Application and human review
EmpCo primarily complements the rules for commercial practices directed at consumers. Check the applicable national implementation separately; Germany’s UWG does not automatically govern claims in other countries. Precise wording alone does not replace matching evidence or a responsible person’s decision before publication. Review the overall impression, including the heading, image and immediately visible explanation. Automated findings do not approve a claim.
Snapshot and limits
The 5,235 documented decisions belong to the working snapshot of 22 September 2026. They have their own denominator, separate from 34,529 captured statements and the risk subset of 17,467 statements. Rounded decision shares are 55.8 percent rewording, 36.9 percent acceptance, 5.1 percent exclusion and 2.2 percent removal. These non-representative records measure neither greenhushing nor legal violations or the effect of a rewrite. Do not combine them with the separate Monitor snapshot of 27 September.
Sources

About the author
Marco Giraldo · Founder of VERDAI
Marco Giraldo is the founder of VERDAI. His work focuses on evidence-based sustainability communication and practical claim management.
VERDAI is an independent orientation tool. This post does not replace legal advice.


