Article

Tackling Greenwashing: Singapore’s Approach and APAC’s Evolving Regulatory Landscape

May 15, 2025

Singapore shows leadership in a diverse APAC market where the race is on to strengthen transparency in environmental claims and combat greenwashing.

As sustainability becomes integral to corporate strategy, the risk of greenwashing — the practice of exaggerating the environmental benefits of products or services — faces heightened scrutiny. Regulatory authorities globally are increasingly focused on ensuring transparency and accuracy in sustainability claims.

Although Singapore has no single law that expressly targets greenwashing, the Lion State has been utilizing its existing legal toolbox in assertively pursuing greenwashing cases.

In this article, we look at the current legal and regulatory framework in Singapore and how it is being used. We also summarize the legal and regulatory frameworks that address greenwashing in other key Asia-Pacific (APAC) markets.

Regulatory Framework in Singapore

In Singapore, greenwashing is not explicitly defined by a single piece of legislation and is addressed through a combination of laws, regulations, and codes, including:

the Consumer Protection (Fair Trading) Act 2003 (CPFTA);
the Misrepresentation Act 1967;
the Singapore Code of Advertising Practice (SCAP);
the Listing Rules of the Singapore Exchange (SGX) and related guidelines;
the Securities and Futures Act 2001 (SFA); and
Monetary Authority of Singapore (MAS) guidelines and circulars.

General Consumer Protection Laws and Enforcement Agencies
Laws/Codes: CPFTA Misrepresentation Act SCAP Enforcement Agencies: CCCS CASE Singapore Tourism Board ASAS	Unfair Practices: The CPFTA protects consumers from unfair practices, including greenwashing. Overseen by the Competition and Consumer Commission of Singapore (CCCS), the CPFTA prohibits false or misleading claims about products or services. Although greenwashing is not explicitly mentioned, the CPFTA’s broad provisions encompass situations in which businesses overstate environmental impacts. Recent parliamentary discussions have reaffirmed the CPFTA’s role in addressing greenwashing, with the CCCS actively developing guidelines to clarify environmental claims that could constitute unfair practices. Enforcement of the CPFTA involves the Consumers Association of Singapore (CASE) and the Singapore Tourism Board as initial points of contact for consumer complaints. Persistent offenders are referred to the CCCS, which has extensive investigative powers, including document requisition and premises entry. Greenwashing can result in civil liability under the CPFTA, common law misrepresentation, and the Misrepresentation Act 1967. Consumers misled by false environmental claims may seek restitution or damages. Businesses must ensure that their environmental statements are accurate, substantiated, and free from exaggeration to avoid potential legal challenges. The CCCS can also seek court injunctions against non-compliant businesses, with further legal consequences for contempt of court. In 2023, a study commissioned by the CCCS highlighted issues with vague and technical language in online product claims, underscoring the need for clear and credible evidence in environmental marketing. Currently, the CCCS is preparing guidelines to provide clarity on environmental claims under the CPFTA. No such guidelines have been published at the time of this publication; however, in the meantime, CCCS and CASE have jointly developed a set of tips to help consumers better understand environmental claims made by businesses, which is published in their websites. The CCCS’s forthcoming guidelines will likely emphasize specificity, transparency, and consumer-friendly language in environmental claims, aligning with broader regulatory efforts to ensure fair trading practices. Advertising Standards: The SCAP, administered by the Advertising Standards Authority of Singapore (ASAS), establishes ethical guidelines for advertising, mandating that environmental claims be clear, substantiated, and not misleading. Although the SCAP does not carry the force of law, ASAS holds the authority to mandate amendments or the removal of advertisements that violate these standards. ASAS has taken two notable enforcement actions against misleading green claims in advertising. The most recent case involved a promotional campaign by Southeast Asian airline, which was banned for making unsubstantiated environmental claims in its “Green Friday” promotion in November 2024. In 2023, ASAS criticized a Singaporean electronics retailer for an advertisement that misleadingly suggested using its air conditioner was the “best tip” to “save Earth,” due to its significant energy consumption.

General Consumer Protection Laws and Enforcement Agencies

Laws/Codes:

CPFTA
Misrepresentation Act
SCAP

Enforcement Agencies:

CCCS
CASE
Singapore Tourism Board
ASAS

Unfair Practices:

The CPFTA protects consumers from unfair practices, including greenwashing.
Overseen by the Competition and Consumer Commission of Singapore (CCCS), the CPFTA prohibits false or misleading claims about products or services.
Although greenwashing is not explicitly mentioned, the CPFTA’s broad provisions encompass situations in which businesses overstate environmental impacts.
Recent parliamentary discussions have reaffirmed the CPFTA’s role in addressing greenwashing, with the CCCS actively developing guidelines to clarify environmental claims that could constitute unfair practices.
Enforcement of the CPFTA involves the Consumers Association of Singapore (CASE) and the Singapore Tourism Board as initial points of contact for consumer complaints.
Persistent offenders are referred to the CCCS, which has extensive investigative powers, including document requisition and premises entry. Greenwashing can result in civil liability under the CPFTA, common law misrepresentation, and the Misrepresentation Act 1967. Consumers misled by false environmental claims may seek restitution or damages.
Businesses must ensure that their environmental statements are accurate, substantiated, and free from exaggeration to avoid potential legal challenges. The CCCS can also seek court injunctions against non-compliant businesses, with further legal consequences for contempt of court.
In 2023, a study commissioned by the CCCS highlighted issues with vague and technical language in online product claims, underscoring the need for clear and credible evidence in environmental marketing.
Currently, the CCCS is preparing guidelines to provide clarity on environmental claims under the CPFTA. No such guidelines have been published at the time of this publication; however, in the meantime, CCCS and CASE have jointly developed a set of tips to help consumers better understand environmental claims made by businesses, which is published in their websites.
The CCCS’s forthcoming guidelines will likely emphasize specificity, transparency, and consumer-friendly language in environmental claims, aligning with broader regulatory efforts to ensure fair trading practices.

Advertising Standards:

The SCAP, administered by the Advertising Standards Authority of Singapore (ASAS), establishes ethical guidelines for advertising, mandating that environmental claims be clear, substantiated, and not misleading.
Although the SCAP does not carry the force of law, ASAS holds the authority to mandate amendments or the removal of advertisements that violate these standards.
ASAS has taken two notable enforcement actions against misleading green claims in advertising. The most recent case involved a promotional campaign by Southeast Asian airline, which was banned for making unsubstantiated environmental claims in its “Green Friday” promotion in November 2024.
In 2023, ASAS criticized a Singaporean electronics retailer for an advertisement that misleadingly suggested using its air conditioner was the “best tip” to “save Earth,” due to its significant energy consumption.

SGX Listed Companies
Laws/Codes: SGX Listing Rules Enforcement Agency: SGX	Corporate Reporting Obligations for SGX-listed companies: The Singapore Exchange (SGX) has implemented mandatory climate reporting for SGX-listed companies, with a phased approach based on industry-specific climate risks. Starting in 2022, the “comply or explain” framework requires companies to disclose their environmental impact and performance or provide a rationale for non-disclosure. Following the guidelines from the Task Force on Climate-related Financial Disclosures, SGX expanded these requirements, initially targeting sectors with significant climate risks. By 2023, this mandate included the financial, agriculture, food and forest products, and energy industries, with the materials, buildings, and transportation sectors required to comply starting from 2024. While SGX has the authority to enforce compliance with its listing rules, the specific consequences for non-compliance with the environmental reporting requirements have not been published.

SGX Listed Companies

Laws/Codes:

SGX Listing Rules

Enforcement Agency:

Corporate Reporting Obligations for SGX-listed companies:

The Singapore Exchange (SGX) has implemented mandatory climate reporting for SGX-listed companies, with a phased approach based on industry-specific climate risks.
Starting in 2022, the “comply or explain” framework requires companies to disclose their environmental impact and performance or provide a rationale for non-disclosure.
Following the guidelines from the Task Force on Climate-related Financial Disclosures, SGX expanded these requirements, initially targeting sectors with significant climate risks.
By 2023, this mandate included the financial, agriculture, food and forest products, and energy industries, with the materials, buildings, and transportation sectors required to comply starting from 2024.
While SGX has the authority to enforce compliance with its listing rules, the specific consequences for non-compliance with the environmental reporting requirements have not been published.

MAS-Regulated Fund Managers
Laws/Codes: SFA MAS Circular CFC 02/2022 Disclosure and Reporting Guidelines for Retail ESG Funds Enforcement Agency: MAS	Financial Services and Environmental, Social, and Governance (ESG) Standards: MAS has issued guidelines to enhance transparency and accountability in ESG standards within the financial sector, particularly for retail ESG funds. Effective January 2023, MAS-licensed fund managers are required to disclose the ESG focus, criteria, and methodologies of their investments, ensuring that the fund’s name and strategy accurately reflect its ESG objectives. Additionally, at least two-thirds of the fund’s net asset value must align with its stated ESG strategy. In December 2023, MAS’ Green Finance Industry Taskforce has also launched the Singapore-Asia Taxonomy for Sustainable Finance to classify green and transitioning activities, among others, facilitating a gradual shift towards environmental sustainability across various sectors, including agriculture, industry, and technology. In terms of enforcement, MAS can take action under the SFA if a collective investment scheme issuer makes materially false or misleading statements that could influence securities transactions or market prices. This includes false environmental claims, with penalties for violations including fines up to S$250,000, imprisonment for up to seven years, or both. MAS’ regulatory framework aims to prevent greenwashing by ensuring that financial products marketed as environmentally sustainable are genuinely aligned with their environmental claims.

MAS-Regulated Fund Managers

Laws/Codes:

SFA
MAS Circular CFC 02/2022 Disclosure and Reporting Guidelines for Retail ESG Funds

Enforcement Agency:

Financial Services and Environmental, Social, and Governance (ESG) Standards:

MAS has issued guidelines to enhance transparency and accountability in ESG standards within the financial sector, particularly for retail ESG funds.
Effective January 2023, MAS-licensed fund managers are required to disclose the ESG focus, criteria, and methodologies of their investments, ensuring that the fund’s name and strategy accurately reflect its ESG objectives.
Additionally, at least two-thirds of the fund’s net asset value must align with its stated ESG strategy.
In December 2023, MAS’ Green Finance Industry Taskforce has also launched the Singapore-Asia Taxonomy for Sustainable Finance to classify green and transitioning activities, among others, facilitating a gradual shift towards environmental sustainability across various sectors, including agriculture, industry, and technology.
In terms of enforcement, MAS can take action under the SFA if a collective investment scheme issuer makes materially false or misleading statements that could influence securities transactions or market prices. This includes false environmental claims, with penalties for violations including fines up to S$250,000, imprisonment for up to seven years, or both. MAS’ regulatory framework aims to prevent greenwashing by ensuring that financial products marketed as environmentally sustainable are genuinely aligned with their environmental claims.

Overview of Greenwashing Regulations in Other APAC Regions

Singapore’s framework is on par with the more developed frameworks in the APAC region, such as Australia and Japan. However, Singapore distinguishes itself through its integrated approach across various sectors.

The Singapore regime is notably proactive, consistently enhancing its reporting requirements and working towards enacting specialized legislation to combat greenwashing. A study by Greenpeace East Asia and CarbonCare InnoLab supports this view, highlighting that Singapore, despite having substantial assets and investments in carbon-intensive sectors, has demonstrated its commitment to phasing out financing for fossil fuel projects. Additionally, Singapore has implemented more stringent ESG reporting requirements compared to other neighboring regions.

Other APAC regions exhibit varying levels of regulatory maturity and enforcement regarding greenwashing.

In the APAC region, Australia stands out with its robust consumer protection laws and active enforcement by the Australian Competition and Consumer Commission (ACCC) and the Australian Securities and Investments Commission (ASIC), which has been effective in curbing misleading environmental claims.

Meanwhile, China and India face challenges due to inconsistent enforcement and a lack of standardized criteria, although both countries are making strides towards greater accountability.

Emerging markets like Indonesia and Vietnam are in the early stages of regulatory evolution, with efforts underway to enhance oversight and consumer education. Below, we explore the specific contexts of several major countries in the area:

Australia

Australia has been at the forefront of addressing greenwashing, with robust consumer protection laws and active regulatory bodies such as the ACCC. The ACCC has issued guidelines to help businesses avoid making misleading environmental claims and has taken enforcement actions against companies found guilty of greenwashing. Australian consumers are generally well-informed and demand transparency, which has led to a market where genuine sustainability efforts are more likely to be recognized and rewarded.
Since July 1, 2022, ASIC achieved 23 corrective disclosure outcomes, issued 13 infringement notices, and commenced one civil penalty proceeding against a financial services firm for greenwashing conduct, in addition to two ongoing civil penalty proceedings against financial services providers. Since 2005, the ACCC has commenced nine formal court proceedings related to greenwashing, accepted 11 court enforceable undertakings, issued infringement notices with penalties in two cases, and encouraged companies to voluntarily address greenwashing concerns in four cases.

Japan

In Japan, the government has implemented stringent regulations to ensure the accuracy and verifiability of environmental claims. In 2023, the Financial Services Agency (FSA) intensified its efforts against greenwashing, prompted in part by a US$9 billion fund managed by a major financial institution that failed to provide sufficient information about its environmental impact. In response, the FSA established new, more restrictive rules for funds using ESG labels. According to these guidelines, only funds that consider ESG as a “key factor” in investment decisions can be marketed with ESG-related terms such as “green” or “sustainable.” Additionally, effective October 1, 2024, amendments to Japan’s Unjustifiable Premiums Act have introduced stricter penalties and a commitment procedure to enhance enforcement by the Consumer Affairs Agency, requiring businesses to ensure the appropriateness of their advertising content.

South Korea

South Korea has made significant strides in promoting sustainability, backed by strong government support for green technology and innovation.
The Korean Fair Trade Commission (KFTC) is proactive in issuing administrative actions for violations of the Labeling and Advertising Act. South Korea is also among the first nations in East Asia to draft legislation imposing fines on firms for false or exaggerated green claims, as companies in the region face increased scrutiny over their environmental credentials and net zero emissions pledges.
As of September 1, 2023, KFTC revised the “Environmental Labeling and Advertising Review Guidelines,” signaling an anticipated tightening of regulations on false or exaggerated environmental claims. Additionally, civil organizations focused on climate and environmental issues are actively engaging with major companies regarding their impact on climate change and the environment. These organizations are particularly vigilant about corporate greenwashing practices and have reported numerous companies to the Ministry of Environment and the KFTC.

Hong Kong

The Hong Kong government has been proactive in promoting sustainability through initiatives like the Green and Sustainable Finance Cross-Agency Steering Group, which aims to align financial practices with environmental goals.
However, a study conducted by Greenpeace East Asia and CarbonCare InnoLab concluded that Hong Kong still lacks comprehensive policies and measures to tackle greenwashing. Currently, Hong Kong relies on its Trade Descriptions Ordinance and guidelines from the Hong Kong Exchanges and Clearing Limited to prevent greenwashing, whereas Singapore, Tokyo, and Seoul have strengthened reporting requirements or are enacting specialized legislation to address the issue.

As sustainability becomes a pivotal element of corporate strategy, the regulatory landscape surrounding greenwashing is evolving rapidly. Singapore has taken significant strides in addressing greenwashing through a multifaceted approach involving various legislative frameworks and regulatory bodies. The Consumer Protection (Fair Trading) Act, the Singapore Code of Advertising Practice, and the Securities and Futures Act, among others, collectively work to ensure that sustainability claims are accurate, substantiated, and transparent.

Endnotes

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