Greenwashing and energy storage: How to avoid overselling your BESS investment

A battery energy storage system can be a sensible part of an energy strategy. But the moment the investment has to be described externally, a trap appears that many companies do not see coming: the temptation to tell a greener story than can be documented. That is the core of greenwashing, and it is a growing compliance topic, not only a question of reputation.

This article explains what greenwashing means in an energy and hardware context, which overclaims most often appear around batteries, what requires documentation rather than vague narrative, and how responsibility is shared between us as supplier and you as the sender of the final communication. At the end there is a practical checklist you can use before a sustainability text goes live.

What greenwashing means when you buy energy equipment

Greenwashing is not necessarily deliberate deception. It arises just as often when a real, but limited, environmental benefit is framed as a larger and more general gain than it is. In a Danish context, the framework is the Marketing Practices Act (markedsføringsloven). When a company presents itself or its products as less harmful to the environment than others, it must be able to document that this is true, and the statements must be correct, relevant and balanced.

In an energy and hardware context this is especially relevant, because a BESS system can easily end up carrying a narrative it cannot deliver on its own. A battery does not in itself use green electricity. It shifts consumption and production in time, and how green the shifted electricity is depends on the grid and on when the system charges and discharges. The benefit is real, but it is conditional. The Danish Consumer Ombudsman's (Forbrugerombudsmanden) recommendations on environmental marketing are an interpretive contribution to the Marketing Practices Act's rules on misleading claims and documentation, and breaches of the prohibition on misleading claims can be punished with a fine. So it is not only credibility that is at stake.

Typical overclaims in energy storage

Some formulations recur when batteries and green electricity are described. They are also the ones that most often do not hold up.

• "CO₂-free" or "CO₂-neutral": A system is rarely without a climate footprint when the full life cycle is counted, from cell production to transport and disposal. From 27 September 2026, under EU rules it will be prohibited to call something climate-neutral or CO₂-neutral when the claim is based on climate compensation, because such statements give a misleading impression of the actual effect.
• "100% renewable" or "green electricity": General green statements such as "green", "climate-friendly" or "environmentally friendly" are perceived by most people as an overall endorsement of the product. That type of statement places strict requirements on documentation, and the product must environmentally belong among the absolute best comparable products.
• "Climate-neutral operations": Claims about future climate neutrality are not in themselves prohibited, but they are only lawful if they are supported by clear, verifiable commitments in a detailed and realistic implementation plan, which is followed by an independent third party. An intention is not enough.

Common to all three is that they describe the whole company or the whole system, while the actual benefit typically concerns only a part. Precisely that type of statement will, from 27 September 2026, be on the EU list of marketing that is in any case considered misleading when an environmental claim applies to the whole product, but the benefit only concerns parts of it.

What requires documentation, and what is general narrative

The line between a lawful and a problematic green text rarely turns on whether something sounds nice. It turns on whether the claim is a statement about an actual circumstance that must be documentable.

The more concrete a statement is, the easier it is to stand behind. A precise piece of information about a single, bounded property is easier to document than a broad claim about being green. If a general statement is used, it must as a rule be documented for the product's full life cycle, that is manufacturing, use and disposal, and the documentation must be confirmable by independent specialists.

Two cases from the Danish Consumer Ombudsman show where this goes wrong in practice. In one, a company used statements such as being produced without plastic and emitting 94% less CO₂, but could not document it, among other reasons because the products were made of bioplastics and still had a non-negligible environmental impact. In the other, a company had commissioned a life cycle assessment, but it could not support general environmental statements, because it only concluded on climate and not on other environmental aspects. The point in both cases is the same: partial or climate-focused documentation cannot carry a broad green claim.

The general narrative that a battery can support the electricity grid and better utilisation of renewable energy is, by contrast, unproblematic in principle, as long as it is kept qualitative and with stated assumptions. Flexibility from batteries can contribute to better use of the grid, and flexibility can in some cases defer or reduce the need for grid expansion. That is a system-level observation, not a quantified saving for the individual installation, and it should be formulated accordingly.

Upcoming EU rules tighten the requirements

The rules are not static. The Danish Consumer Ombudsman has updated its practice and incorporated the forthcoming amendment to the Marketing Practices Act that implements the EU rules, and the new requirements take effect on 27 September 2026. The change comes from the Empowering Consumers Directive, which was adopted in February 2024 and expands the prohibition on misleading environmental claims.

The rules are formally aimed at communication to consumers, but they are also relevant in a business context, among other reasons because several countries apply the principles broadly, and because a business customer may end up repeating a supplier's statements further. A separate proposal, the so-called Green Claims Directive, would add requirements that green statements be documented and verified by an accredited third party before they are used. That proposal has, however, not yet been adopted, and its further fate is unresolved, so it should not be treated as current law today. The direction is nevertheless clear: documentation and precision are becoming more important, not less.

A checklist before you publish a sustainability text

The points below are not legal advice, but a practical way to test a green formulation before it is published. They follow the logic the Danish Consumer Ombudsman applies.

• Documentation first: Can the claim be documented already when the text is published, and can the documentation be confirmed by independent specialists? If not, the claim should be rephrased or removed.
• Scope and boundaries: Is it clear whether the statement applies to the company, a single activity or a product? A benefit that only concerns a part must not appear as a property of the whole product or company.
• Method and comparison: If you compare, what is being compared with, and by which method? A life cycle assessment that only covers climate cannot support a broad environmental claim.
• Avoid absolutes: Formulations such as CO₂-free, 100% renewable or climate-neutral operations require documentation that few systems can deliver. Future targets are only lawful with a verifiable and independently monitored plan.
• Build on facts, not atmosphere: Colours, images and design also form part of the assessment of whether a text is misleading. A concrete, bounded statement is easier to stand behind than a vague promise about values.

ZynexGroup's approach to system assessment

We develop, deliver and optimise industrial BESS systems and make operational data available. That is our field. We are not ESG advisers or CSRD consultants, and we do not produce sustainability reports or final communication texts for the customer. Our contribution is hardware, commercial optimisation of the system's flexibility, and access to the operational data that the customer and their own advisers can use in their own documentation.

That division is not accidental, and it has a legal core. As a starting point, it is the company that markets itself that is responsible for compliance with the Marketing Practices Act, and that can incur liability for a statement. When you describe your system in an annual report, on the website or in a tender, you are the sender, and you must be able to document the statement. We can provide operational data that describe the system's actual activity, but we cannot take over responsibility for a claim we are not the sender of. That is why a sober description you can stand behind yourself is far more durable than a green headline no one can document. How this can be formulated in practice without overclaim is covered further in an article on internal and external communication of a BESS investment, and the question of when a battery can be said to shift green electricity is addressed in an article on CO₂ displacement.

Overall perspective

Greenwashing is rarely the result of bad faith. It arises when a real but bounded benefit becomes a broad, undocumented claim. For a BESS system, the useful point is that the benefits of flexibility and better utilisation of renewable energy are worth talking about, but they should be formulated qualitatively and with assumptions, not as CO₂-free or climate-neutral operations.

With the tightened rules from 27 September 2026, precision and documentation only become more important. The safest path is to say less and be able to document it, rather than say a lot and risk a formal warning from the Consumer Ombudsman. A battery investment stands strongest when the story about it is as solid as the system itself.

Get an assessment of your facility's potential

If you want clarity on what a battery energy storage system can realistically contribute at your site, we are happy to have a data-based conversation. We start from your own data: grid connection, consumption profile and history. On that basis we make an initial assessment of whether there is a match, and which operational data a system could then make available for your own reporting. You are welcome to contact us.