Greenwashing: impact of Legislative Decree 30/2026 on B2B Companies

With Legislative Decree No. 30 of 20 February 2026, Italy has transposed Directive (EU) 2024/825, introducing a significantly stricter regime for unfair commercial practices. This is particularly relevant to environmental claims, product durability, and repairability.

The decree is formally in force from 24 March 2026 but will be applicable from 27 September 2026, allowing businesses a period for adjustment. These new provisions directly affect the Consumer Code (Legislative Decree 206/2005) and form part of the broader European policy framework aimed at combating greenwashing and promoting sustainable consumption models.

CONTENTS

1. Scope of application: a regulation designed for B2C
2. Public procurement and Green Public Procurement
3. Commercial communication and reputational risk
4. A proactive approach: from compliance to strategy

1. SCOPE OF APPLICATION: A REGULATION DESIGNED FOR B2C ↑

It is important to clarify from the outset that the provisions introduced by Legislative Decree 30/2026 apply exclusively to relationships between professionals and consumers. “Consumer” refers to a natural person acting for purposes unrelated to their business or professional activity. Consequently, companies operating solely in the B2B sphere or with Public Administration (B2G) are, from a formal perspective, excluded from direct application of the new rules. The information obligations, prohibitions on misleading commercial practices, and new legal definitions are designed to protect the end consumer. However, stopping at this observation risks providing an incomplete understanding of the issue.

Indirect Impacts and “Cascade Effect” Along the Supply Chain

Despite the absence of direct obligations, the new regulation is expected to produce significant indirect effects along value chains, with tangible impacts on B2B companies. In particular, industrial or commercial clients of a supplier may themselves be subject to transparency obligations towards the end consumer. This means that:

• They may begin systematically requesting environmental data, information on durability and repairability of purchased components;
• Supply contracts may include specific clauses relating to certifications, environmental performance, availability of spare parts, or guarantees of durability;
• The supplier’s ability to provide clear, verifiable information consistent with the new regulatory standards becomes a genuine competitive factor.

Companies unable to support their clients in compliance processes risk, in the medium term, being penalised or excluded from supply chains.

2. PUBLIC PROCUREMENT AND GREEN PUBLIC PROCUREMENT ↑

Another area of impact is public procurement. Public Administrations are increasingly bound to apply Minimum Environmental Criteria and Green Public Procurement principles. Although Legislative Decree 30/2026 is formally aimed at B2C, the definitions introduced (environmental claim, sustainability label, certification system, durability) are set to become reference parameters in tender procedures. It is therefore likely that contracting authorities will require, as minimum requirements or award criteria:

• Demonstration of specific environmental performance;
• Absence of communications that could be classified as greenwashing;
• Documentary evidence regarding the durability and repairability of offered products.

3. COMMERCIAL COMMUNICATION AND REPUTATIONAL RISK ↑

Even for companies operating in the B2B sector, commercial communication (websites, brochures, presentations, industry fairs) is considered inherently public. The use of generic environmental claims not supported by objective and verifiable data (such as “eco‑friendly”, “green”, “sustainable”), while not always directly sanctionable, exposes the business to increasing reputational risks. The new regulatory framework sets a higher standard of diligence, which is expected to influence B2B market practices as well.

4. A PROACTIVE APPROACH: FROM COMPLIANCE TO STRATEGY ↑

In light of the above, even in the absence of immediate obligations, it is advisable for businesses to adopt a proactive approach, beginning now to align with the new principles. Specifically, it is recommended to:

• Review commercial communications to identify and correctly qualify any environmental claims;
• Structure the collection of data relating to durability, repairability, availability of spare parts, and environmental performance;
• Verify that any labels or certifications used are based on certification systems compliant with regulatory criteria;
• Initiate dialogue with key clients to anticipate their future information needs.

Adapting to these new standards is not merely a matter of regulatory compliance, but a strategic choice to strengthen the company’s competitive positioning and reliability within the supply chain.

Actions to Take by September 2026

Ahead of the application of Legislative Decree 30/2026 from 27 September 2026, even companies operating predominantly in B2B or B2G should begin a process of review and adaptation, with a structured and documented approach. Specifically, it is recommended to:

1. Map existing environmental claims. Conduct a comprehensive review of all company communications (website, brochures, catalogues, technical data sheets, commercial presentations, exhibition materials) to identify any environmental claims, including implicit ones;
2. Verify the robustness of statements. For each claim identified, assess whether it:
   • Is sufficiently specific and not generic,
   • Is supported by objective, measurable, and verifiable data,
   • Relates to the entire product/activity or only certain aspects (avoiding misleading statements);

3. Collect and structure product data. Initiate an internal process to gather and organise information relating to:
   • Product durability (ability to maintain functions and performance over time),
   • Repairability (availability of spare parts, ordering procedures, maintenance instructions),
   • Any environmental certifications, verifying their compliance with the requirements of a credible and transparent certification system;

4. Analyse contracts and supply chain relationships. Review existing supply contracts and commercial practices to identify:
   • Possible “cascade” information requests from clients,
   • Current or future clauses regarding sustainability, environmental performance, durability, and compliance;

5. Coordinate communication, technical and legal areas. Ensure effective alignment between company functions (commercial, technical, quality, legal) so that information disseminated to the market is consistent, controlled, and defensible;
6. Adopt a documented and defensive approach. Structure a preventive compliance process, useful not only for regulatory purposes, but also to:
   • Reduce reputational risk,
   • Strengthen competitive positioning,
   • Respond promptly and credibly to requests from clients and Public Administrations.

CARAVATI PAGANI remains available to support businesses in analysing the impacts of the new regulation and in reviewing commercial communication, technical documentation, and supply contracts. We guarantee a structured compliance and strategic service, delivered by our lawyers and accountants.