Greenwashing of Electric Vehicles in Poland – Environmental Claims and Legal Risks

Last updated: 24.08.2026

Greenwashing in electric vehicle sales may involve misleading claims, false environmental claims or unverified environmental claims concerning the environmental benefits of a vehicle, fleet or service. Such statements may affect consumers’ purchasing decisions, particularly when marketing communications are not supported by complete and verifiable data.

For EV importers, car dealers, corporate fleet operators and charger manufacturers, compliance requires reviewing environmental claims across all advertising channels and ensuring that their marketing practices comply with EU and Polish rules aimed at protecting consumers.

What is Greenwashing in the Electric Vehicle Market?

Using environmental and ecological themes and catchphrases related to zero emissions as a main selling argument – so-called green claims – in marketing communications has become subject to strict scrutiny by consumer protection authorities.

Greenwashing electric vehicles Poland is defined as a practice consisting of creating a false or exaggerated impression among recipients that a company’s product, service or activity has a beneficial or positive impact on the environment, when in reality this impact is limited, unverifiable or concerns only a narrow slice of the entrepreneur’s activity.

Such greenwashing practices may involve presenting false information, omitting relevant data or exaggerating the eco friendliness of a product or service.

European Union Rules on Greenwashing Practices – Directive 2024/825 and Draft UC111

Currently, the fight against advertising manipulation is based on the general Act on Counteracting Unfair Market Practices.

However, a fundamental change is introduced by European Union Directive 2024/825, which from 27 September 2026 creates an absolute catalogue of practices recognized as unfair under all circumstances – the so-called blacklist of prohibited practices.

The requirement to prove each time before an authority that a customer was actually misled is eliminated. The mere fact of using a prohibited phrase or one of the listed false claims constitutes an automatic violation of the law.

The government project for implementing the directive into the Polish legal system, marked as draft no. UC111 and published in August 2025, does not provide for transitional provisions.

This means that materials prepared currently, but distributed after September 2026, are subject to evaluation under the new criteria. As a result, marketing departments of importers and dealers may unknowingly violate the greenwashing law in Poland by continuing to use such practices.

Prohibited Environmental Claims in Electric Car Advertising

When analysing the marketing of electric vehicles, the regulations categorically eliminate the following expressions and marketing practices from promotional campaigns.

• Generic, unsubstantiated environmental claims: Slogans like “eco-car”, “green choice”, “nature-friendly”, “eco friendly”, or “sustainable” will be strictly forbidden if the business does not demonstrate recognized, high environmental performance supported by hard data. The same applies to broad sustainability claims and other vague terms suggesting that electric vehicles are automatically sustainable products without identifying the specific basis for such a statement.
• The phrase “zero-emission car” / “emission-free” without specifying the context: An electric vehicle does not emit CO₂ only while driving – from the tailpipe. However, the raw material extraction process, battery production and charging from a coal-based grid or electricity generated using fossil fuels may generate emissions and have a negative environmental impact. Using this catchphrase in relation to the entire vehicle, without adding “at the place of use” or “during driving”, constitutes a direct violation of the law. UOKiK is already conducting proceedings (including against Bolt) precisely for using catchphrases about “emission-free vehicles” and “100% renewable energy” in relation to a fleet run mainly with internal combustion cars.
• Declarations of climate neutrality based exclusively on offsets: It is strictly forbidden to formulate slogans suggesting environmental neutrality – “carbon neutral” – solely on the basis of purchasing external certificates and using carbon offsets, without real reduction investments in the supply chain.
• Private eco-labels and certificates: The use of self-created graphic logos such as “Green Dealer Certificate” without passing an authorized certification system by an independent, accredited institution is directly banned. A company cannot demonstrate the eco friendliness of its activity merely by creating its own label and making claims that are not supported by independent verification.
• Presenting a fragment of activity as a whole: Promoting a showroom as “zero-emission” because it uses LED light bulbs, or promoting a “green fleet” when only demonstration cars are electric, constitutes an illegal action. This form of selective presentation may create the impression that the entire company or fleet provides environmental benefits, even though the claim relates only to a limited part of its activity.

UOKiK Enforcement of Greenwashing Practices in the Automotive Industry

UOKiK is intensively enforcing the ban on greenwashing even before the new regulations enter into force.

The greenwashing cases initiated in 2025–2026 directly concern the transport and automotive industries, which provides practical guidance for EV dealers and importers.

UOKiK Proceedings Against Bolt

UOKiK’s reservations concern communications about “emission-free vehicles” and “100% renewable energy”. The Office indicates that the message could suggest a dominant share of electric vehicles in the provision of services, whereas in practice they are provided mainly by internal combustion cars. If the allegations are confirmed, fines can reach up to 10% of turnover for each challenged practice.

UOKiK Proceedings Against DPD, DHL, InPost and Allegro

DPD presented itself as a leader in sustainable logistics, promoting slogans such as “green fleet”, “environmentally friendly deliveries”, or “zero emission”. UOKiK points out that this type of message can mislead consumers if it does not refer to the entire scale of the company’s activity or the full delivery process. These proceedings provide specific examples of claims that may violate the rules on protecting the collective interests of consumers.

Communication regarding ecological solutions, such as electric vehicles, should be reliable and account for their environmental impact across the entire lifecycle.

These proceedings, although concerning logistics companies rather than dealers, have direct precedent value for the automotive sector. 

UOKiK’s evaluation mechanism is identical: is the marketing message regarding electric vehicles based on complete, verifiable data and does it reflect the actual scale of activity, or is it only a fragment of activity presented as a whole?

Green Claims Directive, ESPR and Digital Product Passports

In June 2025, the European Commission withdrew the draft directive on green claims – the Green Claims Directive – which planned an obligation for prior verification of every claim by an independent body before publication.

The proposal met with strong political pressure from the European People’s Party due to costs.

However, this withdrawal does not mean a slowdown in regulation. The strict prohibitions of Directive 2024/825 remain in full force, and the lack of a necessity for ex-ante authorization means only that a company does not have to approve a slogan before publication, but must be ready to prove its factual basis in the event of a UOKiK audit.

In parallel, the Ecodesign Regulation – ESPR – will introduce digital product passports.

Combined with the digital battery passport from 2027, these systems will ensure that environmental claims for electric cars become verifiable by consumers in official databases, reducing the scope for corporate greenwashing and manipulation.

Audit of Environmental Claims and Legal Consequences of Greenwashing

In the face of a tightening legal environment, implementing procedures for auditing marketing materials is a necessity for importers and dealers seeking to align their activities with greenwashing rules for electric vehicles in Poland.

The audit should cover all communication channels:

• websites,
• online advertising,
• displays,
• sales representatives’ conversation scripts,
• other advertising campaigns and marketing communications.

Every environmental claim must be verified against the existence of full factual documentation, including data from the Battery Regulation, ISO 14001 certificates and renewable energy guarantees of origin – GOs.

This verification should identify unverified environmental claims, statements based on incomplete data and claims that may create an unjustified impression of environmental benefits.

Legal Consequences of Greenwashing for Importers and Car Dealers

Ignoring these requirements carries serious financial consequences.

The President of UOKiK has the authority to impose administrative financial penalties amounting to up to 10% of the total annual turnover of the enterprise for using unfair market practices, and up to PLN 2 million for managing individuals.

Crucially, the fine is calculated based on the total annual turnover of the entity, and not on the segment concerned by the advertising violation. For a dealer with a PLN 50 million turnover, the penalty may reach PLN 5 million for each challenged practice.

Furthermore, a showroom exposes itself to civil lawsuits from competitors for unfair competition and claims from consumers demanding withdrawal from the contract and a cash refund for the car.

The analysis of these regimes concludes the comprehensive review of issues making greenwashing in the automotive industry and corporate greenwashing a new compliance challenge.

Ensure Your Green Claims Are Legally Compliant

Environmental claims used in the marketing of passenger cars—including comparisons between electric vehicles and traditional vehicles with a combustion engine—can influence consumer behavior and consumer trust. Misleading statements concerning environmental initiatives, environmental protection, climate change or alignment with the European Green Deal may expose a business to regulatory action, financial liability and reputational damage.

Our lawyers support EV importers, car dealers, fleet operators and charger manufacturers in reviewing marketing communications and assessing their potential negative impact.

Contact us before publishing your green claims to ensure that your communication is transparent, verifiable and compliant with applicable consumer protection rules.

FAQ – Greenwashing and Environmental Claims in EV Sales