Greenwashing: Overview (Singapore) - 2026 Updates

Greenwashing: Overview (Singapore) - 2026 Updates

Reproduced from Practical Law with the permission of the publishers. For further information, visit www.practicallaw.com.

With the growing importance of corporate sustainability-related information to consumers, investors, business partners, and employees, the accuracy of this information is coming under increased regulatory scrutiny in Singapore. As a result, misleading or inaccurate claims in sustainability related disclosures or other statements may result in reputational damage, regulatory intervention, and legal action.

What is greenwashing can vary across jurisdictions and between regulators and other enforcement agencies. This Practice Note explains the regulatory approach to greenwashing in Singapore and also sets out the basis on which legal action can be brought.

Greenwashing Concepts and Definitions

At its core, greenwashing refers to the act of misleading third parties by overstating the positive environmental impact of a product, service, brand, or business. However, there are nuances to this concept.

In Singapore, greenwashing is not defined by any legislation or regulation. Rather, the substantive act of greenwashing falls under several laws and regulations.

Greenhushing

Greenhushing (sometimes referred to as greenbleaching), is downgrading, downplaying, or staying silent on the environmental credentials of a product or service to avoid extra regulation, legal sanctions, or reputational damage arising from inadvertent greenwashing or a failure to meet environmental targets. For example, greenhushing occurs when a company deliberately underreports its  environmental, social, and governance (ESG) initiatives for fear of backlash. This underreporting can lead to legal or regulatory penalties or reputational damage. Greenhushing is often a result of over-regulation or a business's lack of understanding of the law.

Advertising and Consumer Laws and Regulations

In Singapore, consumer laws prevent organisations from falsely advertising or marketing themselves or their activities as green. The main piece of legislation is the Consumer Protection (Fair Trading) Act 2003 (CPFTA) (see Consumer Protection (Fair Trading) Act 2003 (CPFTA)).

Regarding advertisements, the Singapore Code of Advertising Practice (SCAP), which is published by the Advertising Standards Authority of Singapore (ASAS) is relevant (see Singapore Code of Advertising Practice (SCAP).

Consumer Protection (Fair Trading) Act 2003 (CPFTA)

The CPFTA protects consumers from unfair practices, which can include greenwashing. The Competition and Consumer Commission of Singapore (CCS) is the primary authority that enforces the CPFTA. CCS is a statutory board under the purview of the Ministry of Trade and Industry (MTI).

In February 2024, the Minister of State for Trade and Industry responded to a parliamentary question on whether the MTI was considering a review of the CPFTA to explicitly prohibit greenwashing by businesses operating in Singapore. In response, the Minister said that the CPFTA protects consumers against businesses that make false or misleading claims about their products or services, including greenwashing. (See MTI: Oral reply to Parliamentary Question on greenwashing.)

Although the CPFTA does not specifically address greenwashing, the law, as written, can capture greenwashing behaviour in the consumer market. CPFTA section 4 is broad enough to include most instances of greenwashing where a supplier misleads consumers by overstating the positive environmental impact of a product, service, brand, or business, such as by making:

• False environmental claims (section 4(b), CPFTA).
• Misleading or deceptive environmental statements or representations (including by omission) (section 4(a), CPFTA).

The Second Schedule of the CPFTA further lists specific examples of unfair practices. Examples that could apply to greenwashing include:

• Representing that goods or services have sponsorship, approval, performance characteristics, accessories, ingredients, components, qualities, uses, or benefits that they do not have.
• Representing that goods or services have a particular standard, quality, grade, style, model, origin, weight, volume, length, capacity, or method of manufacture that they do not.
• Making a representation that appears in an objective form, such as an editorial, documentary, or scientific report, when the representation is primarily made to sell goods or services, unless the representation states that it is an advertisement or a promotion.
• Omitting to provide a material fact to a consumer, using small print to conceal a material fact from a consumer, or misleading a consumer as to a material fact regarding the supply of goods or services.

For more information on consumer protection laws in Singapore, see Practice Note, Contracting with Consumers: Overview (Singapore).

Enforcement of the CPFTA

Under the CPFTA, the Consumers Association of Singapore (CASE) and Singapore Tourism Board (STB) are the respective first points of contact for local consumers' and tourists' complaints. CASE assists aggrieved consumers to obtain redress and, in some cases, compensation through negotiation, mediation, or both.

Errant retailers who persist in unfair trade practices are referred to CCS for investigation, which has extensive powers to address suspected CPFTA violations. CCS can:

• Conduct an investigation if there are reasonable grounds to suspect that:
  • a supplier has engaged, is engaging, or is likely to engage in an unfair practice;
  • a person has knowingly abetted, aided, permitted, or procured a supplier to engage in an unfair practice; or
  • a person is knowingly abetting, aiding, permitting, or procuring a supplier to engage in an unfair practice.

(Section 19, CPFTA.)

• Require the production of documents that are relevant to an investigation (section 20, CPFTA).
• Enter premises with or without a warrant in connection with an investigation (sections 21 and 22, CPFTA).

A person who refuses to provide information, destroys or falsifies documents, provides false or misleading information, or obstructs an officer conducting an investigation or enforcement can be guilty of an offence and liable on conviction to a fine up to SGD10,000, imprisonment up to one year, or both.

If a finding is made following an investigation, CCS can file injunction applications with the courts against persistent errant retailers and enforce compliance with injunction orders issued by the courts. If the supplier under injunction does not comply with the injunction order, CCS can take the supplier to court for contempt of court. This is a criminal offence that could result in a fine, imprisonment, or both.

CPFTA violations can also lead to civil liability (see Civil Liability and Greenwashing Litigation).

CCS Guide on Quality-Related Claims

On 6 October 2025, CCS published the CCS Guide on Quality-Related Claims, following concerns raised over potential greenwashing by businesses found to have made misleading claims.

The Guide provides clarity to suppliers making claims about the quality of their products or businesses, including environmental claims, that could amount to unfair practices under the CPFTA. The Guide is intended to help companies both:

• Make fair and accurate claims about the green credentials of their products.
• Avoid unintentional greenwashing that could amount to an unfair practice under the CPFTA. (See MTI: Written reply to Parliamentary Questions on CCS's Guidelines on product marketing to avoid greenwashing.)

In the Guide, CCS refers to five key guiding principles that businesses should take into account when making claims about the quality of their products and businesses, to avoid unfair trade practices under the CPFTA:

• Claims should be true and accurate.
• Claims should be clear and easily understood.
• Claims should be meaningful.
• Claims should be accompanied by material information.
• Claims should be supportable by evidence.

CCS has also stated that, in conducting its investigations, it will consider whether the supplier has made genuine efforts and taken reasonable steps to verify the accuracy of any information that it has relied on and whether the supplier has acted reasonably in making the claim. CCS will take into account the business's scale and resources in making its assessment of whether the steps taken were reasonable.

The Guide sets out various examples to illustrate and contextualise CCS's application of these guiding principles. Some greenwashing examples CCS has highlighted include:

• A claim of "environmentally sustainable Eco-soft Technology" is likely to be misleading and amount to an unfair trade practice under the CPFTA, as:
  • it is not a conventionally used term;
  • it is unclear what the specific properties or environmental benefits of the product are; and
  • consumers are likely to interpret the claim to mean that the production process has a lower impact on the environment (compared to other production processes).
• A claim that a product is a "greener choice with 27% less packaging" is unlikely to be meaningful as it is unclear what the basis is for comparison.
• A claim that a product is "made of recycled material," when in fact only part of the product is made of recycled material, is misleading and amounts to an unfair trade practice under the CPFTA, as it gives consumers the impression that the entire product was made of recycled material when it was not.

Businesses should familiarise themselves with the Guide to ensure compliance, and prepare themselves for the regulatory risks concerning greenwashing.

CCS's publication of the Guide is reflective of its ongoing efforts to develop clearer guidance on environmental misrepresentations by businesses in Singapore, in light of increasing concerns over greenwashing.

Prior to the release of the Guide, CCS had, in November 2023, advised suppliers to:

• Be specific in their environmental claims by presenting any qualifying or supporting information accurately and clearly alongside the claims.
• Avoid making claims that would imply or convey an overall impression that the environmental benefit of the product is greater than its actual environmental benefit (for example, the degree of recycled material used).
• Ensure that all environmental claims can be substantiated with valid and credible evidence.
• Use language that is easier for consumers to understand.
• Explain the meaning or implications of technical terms.

(See CCS: Study on Greenwashing in Online Marketing Funded by CCCS Finds Use of Vague Environmental Claims and Confusing Technical Jargon.)

While CCS's advice does not have the force of law, it can potentially be persuasive in a CPFTA unfair practices claim. Singapore regulators, including ASAS, may also consider CCS's recommendations in any decisions they make (see Singapore Code of Advertising Practice (SCAP)).

In addition, CCS funded the Study on Greenwashing on E-Commerce sites by National University of Singapore (NUS) Business School in 2023 on environmental claims made on e-commerce sites frequently visited by Singapore residents, which found that:

• 51% of online product claims were found to be vague with insufficient elaboration or supporting details.
• 14% of online product claims use technical language that made it difficult for consumers to understand or verify the claim.

Following the study, CCS concluded that:

• Environmental claims (such as language claiming a product or service is environmentally friendly, eco-friendly, green, sustainable, good for the Earth, natural, conscious, or responsible), may be vague or prone to overstatement or exaggeration regarding the actual environmental benefits.
• Claims that use technical jargon (such as "made of high-quality ABS eco-friendly material") can confuse or mislead consumers about the environmental benefit of a supplier's goods, services, or business.

With the 2025 release of the Guide, CCS continues its regulatory effort to address similar underlying concerns as those arising from the 2023 NUS study, including the need for transparency and evidentiary support, and the avoidance of ambiguous or unqualified claims by businesses about the environmental impact of their products or businesses.

Singapore Code of Advertising Practice (SCAP)

ASAS is a council under CASE that promotes ethical advertising in Singapore. ASAS is a self-regulatory body of the advertising industry that has published the SCAP to promote a high standard of ethics in advertising.

A business that is assessing the regulatory risks of greenwashing in advertising should give due regard to the SCAP. Advertisements that greenwash by overstating the positive environmental impact of a product or business can result in ASAS taking action (see Consequences of Breaching the SCAP).

Under the SCAP, environmental claims should:

• Clearly explain their basis and, where necessary, be qualified, as unqualified claims can mislead if they omit significant information.
• Not be used without qualification unless advertisers can provide convincing evidence that their product will cause no environmental damage (for example, that the product is environmentally friendly or wholly biodegradable). Qualified claims and comparisons (for example, greener or friendly) can be acceptable when an advertiser can substantiate that its product provides an overall improvement in environmental terms either against their competitors' or their own previous products.
• Not suggest that a claim has universal acceptance if it is not true. Where there is significant division of scientific opinion or where evidence is inconclusive, this should be reflected in any statements made in the advertisements.
• Not imply that a product has been changed to make it environmentally safe if the product never had a demonstrably adverse effect on the environment. However, an advertiser can claim a product omits chemicals that are known to damage the environment if the product's composition has been changed or was purposely designed to omit those chemicals.
• Avoid using extravagant language or bogus and confusing scientific terms. The meaning of any necessary scientific expressions should be clear in advertising.

(Chapter IV, Appendix L, SCAP.)

The SCAP's general provisions can also be applicable to greenwashing. Advertisements should not be misleading due to inaccuracy, ambiguity, exaggeration, omission, or otherwise. Specifically, an advertisement should not:

• Misrepresent any matter that is likely to influence a consumer's attitude toward any product, advertiser, or promoter.
• Include information to mislead consumers into believing any untrue matter, such as the source of the product, quality of the product, obligation (or non-obligation) in using a trial product, and others similar matters.

(Chapter II, rule 5.1, SCAP.)

Additionally, an advertisement should not misuse research results or quotations from technical and scientific publications. Scientific jargon and irrelevancies should not be used to make a claim appear to have a scientific basis it does not possess. (Chapter II, rule 4.1, SCAP.)

Businesses must be prepared for increased greenwashing regulation in advertising. Businesses should consider the CCS Guide on Quality-Related Claims when assessing their legal and regulatory risks in Singapore and incorporate the Guide into their internal policies and procedures.

For more information on advertising in Singapore, see Practice Note, Advertising Overview (Singapore).

Consequences of Breaching the SCAP

While the SCAP does not have the force of law, ASAS decisions can have serious consequences for businesses. ASAS can:

• Require an advertiser to amend or remove an advertisement.
• Withhold advertising space or time from advertisers.
• Withdraw trading privileges from advertising agencies.
• Publish the details of an ASAS review, including naming advertisers that breached the SCAP.
• Refer the matter to the relevant authorities for further investigation, such as CCS when ASAS suspects a CPFTA violation.

(Chapter I, rule 6, SCAP.)

ASAS has recently levelled public criticism at advertisements for making greenwashing claims.

In January 2025, ASAS banned a promotional campaign by the Vietnamese budget airline VietJet, after finding that it had breached the SCAP’s requirement for factual substantiation of claims (see Chapter III, rule 1.1, SCAP). VietJet's "Green Friday" promotion marketed its air tickets as a way for travellers to "contribute to a greener future" by flying with VietJet, and highlighted its "modern, fuel efficient and environmentally friendly" aircrafts (see Sustainability Magazine: Inside VietJet's Controversial 'Greenwashing' Campaign).

ASAS found that these claims of reduced fuel consumption and emissions were specific to a particular combination of aircraft type and engine, which made up only part of the VietJet fleet. ASAS's view was that consumers could not be assured of realising the claimed reduction in fuel consumption and emissions. Following ASAS's intervention, VietJet removed communications for its Green Friday campaign from its Singapore channels.

Separately, in December 2023, ASAS found that Prism+, a Singaporean electronics retailer, had breached the SCAP when an advertisement featuring a social media influencer claimed that using the company's air conditioner was the "best tip" to "save Earth" (see Channel News Asia: PRISM+ air-con ad featuring Xiaxue deemed misleading by advertising standards watchdog).

ASAS stated the advertisement breached the SCAP, particularly that advertisements must not mislead by inaccuracy, ambiguity, exaggeration, or omission or misrepresent any matter likely to influence consumers' attitudes to the product (see Chapter II, rule 5.1, SCAP). ASAS viewed the advertisement as unacceptable, given the energy that appliances like air conditioners consume. While Prism+ defended the advertisement as being tongue-in-cheek and satirical, the company removed the advertisement from its Instagram page following ASAS's comments.

Environmental Disclosures in Company Reports

Mandatory Climate Reporting for SGX Listed Issuers

The Singapore Exchange Limited (SGX) has been progressively introducing mandatory climate reporting. In financial year 2022, climate reporting was introduced on a "comply or explain" basis, which requires an SGX-listed issuer to provide an explanation if it does not disclose its social and environmental impact and performance. In-scope companies need to ensure that their environmental disclosures are complete and accurate to mitigate the risk of greenwashing.

Based on the recommendations from the Task Force on Climate-related Financial Disclosures, SGX is phasing in additional reporting requirements, starting with companies that operate in industries that have been identified as having the highest climate-related risks:

• In financial year 2023, climate reporting became mandatory for issuers in the financial, agriculture, food and forest products, and energy industries.
• In financial year 2024, mandatory climate reporting is being extended to the materials, buildings, and transportation sectors.

Disclosure of Greenhouse Gas Emissions by SGX Listed Issuers and Large Non-Listed Companies

SGX and the Accounting and Corporate Regulatory Authority (ACRA) have jointly announced that mandatory climate-related disclosures of greenhouse gas (GHG) emissions will be progressively introduced for SGX-listed issuers and large non-listed companies in Singapore. These disclosures are separate from SGX's mandatory climate reporting (see Mandatory Climate Reporting for SGX Listed Issuers).

Beginning in financial year 2025, all listed issuers must report and file climate-related disclosures on both:

• Direct GHG emissions from owned or controlled sources (Scope 1 emissions).
• Indirect GHG emissions from the generation of purchased energy (Scope 2 emissions).

Beginning in financial year 2030, the same requirements apply to large non-listed companies with an annual revenue of at least SGD1 billion and total assets of at least SGD500 million (ACRA: Sustainability reporting and assurance requirements).

Reports on all Scope 3 emissions (indirect greenhouse gas emissions that occur in the value chain of a reporting company, including both upstream and downstream emissions):

• Are required for Straits Times Index (STI) constituents (the top 30 SGX-listed issuers by market capital) starting in financial year 2026.
• Are voluntary for other SGX-listed companies and large non-listed companies until further notice.

(ACRA: Sustainability reporting and assurance requirements.)

Assurance Requirements for GHG Disclosures

External limited assurance on direct greenhouse gas emissions from owned or controlled sources and indirect greenhouse gas emissions from the generation of purchased energy must be conducted for:

• SGX-listed issuers beginning financial year 2029.
• Large non-listed companies beginning financial year 2032.

Limited assurance has a lower level of assurance and involves fewer tests than that applied to statutory audits of financial statements.

Enforcement of Corporate Reporting Requirements

SGX may take regulatory action if there are breaches of the Listing Rules (see SGX: Enforcement Framework). However, it remains to be seen what enforcement action SGX may take for any failure to comply with the environmental disclosure requirements. For large non-listed companies, we await clarity from ACRA on the possible penalties for breaches.

Regulating Greenwashing in Financial Services

The Monetary Authority of Singapore (MAS) has published guidelines on ESG standards that are applicable to certain financial sectors and can be relevant to greenwashing (MAS: CFC 02/2022 Disclosure and Reporting Guidelines for Retail ESG Funds (CFC 02/2022)). CFC 02/2022 seeks to provide clarity on MAS's expectations of how existing requirements under the Code on Collective Investment Schemes and Securities and Futures (Offers of Investments) (Collective Investment Schemes) Regulations 2005 apply to retail ESG funds and the disclosure and reporting guidelines applicable to these funds.

From January 2023, fund managers for retail ESG funds must disclose both:

• The investment's ESG focus and relevant criteria, methodologies, or metrics.
• The sustainable investing strategies of retail funds sold with an ESG label.

The ESG fund's name cannot be misleading and the fund's investment portfolio or strategy should reflect its sustainable focus. At least two-thirds of the fund's net asset value must be invested in accordance with the stated ESG investment strategy. (CFC 02/2022.)

Separately, MAS's Green Finance Industry Taskforce (GFIT) has suggested a classification system or taxonomy for Singapore-based financial institutions aimed at identifying activities that are considered green or transitioning towards green. The inclusion of transitioning activities allows for a gradual move towards greater sustainability while considering the activities' starting positions and supporting inclusive economic and social development.

The Third GFIT Taxonomy Consultation Paper was released in February 2023 to gather opinions on the specific thresholds and requirements for the classification of green and transitioning activities in the following sectors:

• Agriculture and forestry or land use.
• Industrial.
• Waste and water.
• Information and communications technology.
• Carbon capture and sequestration.

Among other matters, the consultation sought feedback on its "do no significant harm" criteria, where activities that significantly contribute to mitigating climate change should not be carried out in a way that negatively impacts the environmental objectives of:

• Climate change adaptation.
• Protecting healthy ecosystems and biodiversity.
• Promoting resource resilience and the circular economy.
• Pollution prevention and control.

On 28 June 2023, the Fourth GFIT Taxonomy Consultation Paper on the thresholds and criteria for financing the early phase­out of coal-fired power plants under the Singapore-Asia Taxonomy was released.

Enforcement of Financial Services Greenwashing

MAS can take regulatory action under section 199 of the Securities and Futures Act 2001 when an issuer of a collective investment scheme makes a materially false or misleading statement that fulfils the following criteria:

• The statement is likely to:
  • induce the subscription, sale, or purchase of securities; or
  • affect the market price of securities.
• The issuer:
  • does not care whether the statement was true or false; or
  • knew or ought reasonably to have known the statement was false or misleading in a material particular.

This prohibition can apply to a materially false or misleading statement relating to an issuer's environmental claim. A breach of this provision is an offence punishable under section 204 of the Securities and Futures Act 2001, which carries a fine up to SGD250,000, imprisonment up to seven years, or both.

Civil Liability and Greenwashing Litigation

Greenwashing litigation is a developing area of risk. In addition to regulatory liability, civil liability can also arise. Civil claims for greenwashing can be brought under:

• The CPFTA (see Consumer Protection (Fair Trading) Act 2003).
• The common law doctrine of misrepresentation (see Common Law Misrepresentation).
• The Misrepresentation Act 1967 (Misrepresentation Act) (see Misrepresentation Act 1967).

Consumer Protection (Fair Trading) Act 2003

A consumer that has entered a transaction involving an unfair practice under the CPFTA can bring a court action against the supplier (section 6(1), CPFTA). A court that finds a supplier to have engaged in an unfair practice can order:

• Restitution of any money, property, or other consideration that the consumer gave or furnished.
• Damages for any loss or damage the consumer suffered from the unfair practice.
• Specific performance against the supplier.
• The supplier to repair goods or provide parts for goods.
• A variation of the contract between the supplier and consumer.

(Section 7(5), CPFTA.)

An aggrieved consumer can claim up to SGD30,000 or any other amount that the MTI may prescribe (section 6, CPFTA).

Common Law Misrepresentation

Statements that misrepresent the positive environmental impact of a product, service, brand, or business, may give rise to a cause of action under the common law doctrine of misrepresentation.

There are two categories of misrepresentation claim:

• Fraudulent misrepresentation.
• Negligent misrepresentation.

In both instances, the claimant must show a reliance on a false representation. The false representation does not have to be the only factor but must have played a real and substantial part in operating on the mind of the claimant such that the claimant was induced to enter the contract in question and suffered losses as a result (Jurong Town Corp v Wishing Star Ltd (No 2) [2005] SGCA 25, at paragraph 72). Whether this requirement is met depends on the facts of the case.

A fraudulent misrepresentation requires the claimant to show the representor's dishonesty. Dishonesty is a high threshold that requires proof on a preponderance of probabilities (Tang Yoke Kheng (trading as Niklex Supply Co) v Lek Benedict and Others [2005] SGCA 27, at paragraph 14). Damages for a fraudulent misrepresentation claim should compensate the claimant for the loss suffered, such that the court will seek to place the claimant in the same financial position that the claimant would have been in if the deceit had not occurred.

A negligent misrepresentation requires the claimant to show that the representor owed the claimant a duty of care in making the representation, that the representor breached that duty, and that the breach caused damage to the claimant (Bay Lim Piang v Lye Cher Kang [2023] SGHC 13, at paragraph 99). Damages awarded for a negligent misrepresentation claim is limited to losses that are reasonably foreseeable (RBC Properties Pte Ltd v Defu Furniture Pte Ltd [2014] SGCA 62, at paragraph 81).

Misrepresentation Act 1967

A statement that misrepresents the positive environmental impact of a product, service, brand, or business, can also give rise to a cause of action under section 2(1) of the Misrepresentation Act 1967. Under this provision, a claimant must establish that they:

• Entered into a contract after the representor made a misrepresentation to them.
• Suffered loss from the misrepresentation.

If the claimant establishes these facts, the representor is liable unless they can prove they had reasonable grounds to believe, and did believe up to the time the contract was made, that the represented facts were true. The Singapore Court of Appeal has stated that there are two sequential stages to this analysis of the proper basis for damages:

• An objective assessment of the particular facts of the case to determine the representor's subjective belief in the truth of the representation.
• An objective determination of whether the representor had reasonable grounds for holding that belief. (RBC Properties, at paragraph 69.)

The courts have suggested that since section 2(1) of the Misrepresentation Act is the statutory analogue of the common law action for negligent misrepresentation, it may be more appropriate to apply a similar measure of damages (so that the measure of damages would be limited to loss that was reasonably foreseeable) (see Common Law Misrepresentation).