Strategy
Sustainable marketing: growth with purpose in the modern economy
The rules on environmental claims change on 27 September 2026. What a marketing leader has to stop saying, what the evidence on consumer demand actually supports, and how to build growth that holds up under scrutiny.
The end of growth for growth’s sake
For decades marketing was built on one goal: more. More customers, more visibility, more sales. As the economic, environmental and regulatory context changes, the definition of growth is changing with it. Sustainable marketing has moved from a corporate responsibility initiative to a strategic question about whether your growth can survive scrutiny.
Two things make this urgent rather than philosophical. The evidence on what consumers will actually pay for is more complicated than the industry keeps saying. And on 27 September 2026, seven weeks from the date on this article, a set of rules takes effect that makes several claims marketers use every week unlawful in the European Union.
This piece deals with both, and it is deliberately sceptical about the statistics usually deployed here, because most of them do not survive a check.
What the evidence actually says
The figure everyone quotes is that 73 per cent of consumers will pay more for sustainable brands. It comes from Nielsen in 2015, it referred to millennials rather than all consumers, and the global figure that year was 66 per cent. A separate Nielsen figure of 73 per cent, from 2018, measured willingness to change consumption habits, which is a different question. Anyone using it in 2026 is quoting an eleven-year-old number about a different population.
The current picture is more useful, and more demanding.
- People will pay a premium, and a modest one. PwC’s Voice of the Consumer survey of more than 20,000 consumers across 31 countries, published 15 May 2024, found an average stated willingness to pay 9.7 per cent more for sustainably produced goods.
- Stated willingness is not purchase behaviour. Bain surveyed 14,206 consumers across eight countries including the UAE and Saudi Arabia for its September 2025 work, and found consumers saying they would pay up to a 13 per cent premium while sustainability-marketed products carried an average 28 per cent premium in the market. Forty-seven per cent named cost as the main barrier.
- The gap may be a communication failure. Researchers at NYU Stern’s Center for Sustainable Business, writing in May 2026, found sustainability-marketed consumer packaged goods drove nearly 45 per cent of US category growth over thirteen years and grew 4.9 times faster than conventional products, at that same 27 per cent premium. Their reading is that consumers do buy, and companies fail to communicate. Consumer awareness of brand sustainability messaging fell from 50 per cent in 2022 to 31 per cent, on GlobeScan data.
Bain and NYU Stern draw opposite conclusions from the same premium figure. Present only one side of that and a well-read chief executive will take the argument apart. The honest position is that sustainability sells where the product is good, the claim is specific and the price gap is defensible, and it does not sell as a general virtue.
Defining sustainable marketing
Sustainable marketing goes beyond green products and social impact campaigns. It designs strategy around three things that have to hold together:
- The planet. Reducing waste, carbon and consumption impact.
- People. Wellbeing, inclusion and how the business treats those it depends on.
- Performance. Long-term profitability and brand trust.
The defining question is whether your success can scale without harming what sustains it. Where a business can answer that with evidence, it has something rare.
The business case, stated carefully
The claim usually made here is that companies with strong environmental, social and governance credentials outperform peers by 21 per cent on shareholder returns. The 21 per cent is real and it measures something else. Accenture, with the World Economic Forum in September 2021, scored around 4,000 companies and found those with stronger sustainability practices showing an average 21 per cent higher EBITDA margin. That is margin, not shareholder return, it is five years old, and Accenture presents it as correlation rather than cause.
Stated accurately it still supports the argument. Businesses that run sustainability as an operating discipline tend to run other things well too. What it does not support is a promise of outperformance, and from 27 September 2026 repeating an unsubstantiated third-party assertion of that kind is itself an enforceable breach in the European Union.
The stronger commercial case in this region is regulatory. Federal Decree-Law No. 11 of 2024 on the reduction of climate change effects came into force on 30 May 2025 and applies to all public and private entities in the UAE, including free zones. It requires measurement, reporting and management of greenhouse gas emissions to approved methodologies, climate risk assessment and adaptation planning, with fines from AED 50,000 to AED 2,000,000 and doubled penalties for repeat breaches within two years. The data that law forces you to collect is the same data a defensible marketing claim needs.
The rules changed in 2026
This is the section to act on.
European Union. Directive (EU) 2024/825, on empowering consumers for the green transition, applies from 27 September 2026. It prohibits generic environmental claims, including “sustainable”, “green”, “environmentally friendly” and “eco”, unless excellent environmental performance is demonstrated through the EU Ecolabel, an equivalent national scheme or a top energy class. It prohibits outright any claim that a product is carbon neutral, climate neutral or net zero on the basis of greenhouse gas offsetting. It prohibits presenting compliance with minimum legal requirements as a distinctive feature. Sustainability labels now have to come from a public authority or a certification scheme with third-party verification independent of both the scheme operator and the trader. Claims about future environmental performance need time-bound, measurable targets, a detailed implementation plan and regular independent verification that consumers can see.
A related note, because it is widely misreported: the separate EU Green Claims Directive is not incoming law. The Commission announced its intention to withdraw the proposal on 20 June 2025 and it remains blocked. The directive that binds you is the one above.
United Kingdom. The Competition and Markets Authority has had direct enforcement powers since April 2025 under the Digital Markets, Competition and Consumers Act 2024, with penalties up to 10 per cent of global turnover or GBP 300,000, whichever is higher. On 22 January 2026 it published guidance extending liability across the supply chain: a business is responsible for repeating, relying on or passing on a third party’s environmental claim, and intent is irrelevant. A retailer can no longer rely on a supplier’s assurance.
United Arab Emirates. There is no dedicated green claims regime. Environmental claims fall under Federal Law No. 15 of 2020 on consumer protection, which prohibits misleading advertisement with fines from AED 10,000 to AED 2,000,000, and under the Media Regulatory Office advertising rules. The practical point for a UAE business is that advertising into the EU or the UK brings you inside both regimes above regardless of the lighter position at home.
“From 27 September 2026, a carbon neutral claim based on offsetting is prohibited in the EU, whatever the offsets cost you.”
Beyond greenwashing
The biggest threat to sustainable marketing is claiming progress without proof. Consumers are better informed and more sceptical than they were, and a superficial sustainability statement damages trust faster than silence.
Three things make a claim defensible.
- Transparency. Publish the impact rather than the intention, with the measurement basis and the period.
- Accountability. Back every claim with measurable action and independent verification, which is now a legal requirement in the EU rather than best practice.
- Consistency. Build sustainability into daily operations, so the marketing describes what the business does.
A worked caution, using an example close to home. Emirates ran a widely reported A380 demonstration flight on 100 per cent sustainable aviation fuel in November 2023. One of four engines used the fuel, on four tonnes in total. Emirates procured over 28,000 tonnes of sustainable fuel in 2025-26, supports the industry commitment to net zero by 2050, and publishes no company-level absolute reduction target and no passenger-facing offset programme. Every one of those facts is defensible when stated precisely. Compressed into “100 per cent sustainable aviation fuel flight” without the qualifier, it is the construction that produced rulings against Etihad, Lufthansa, Air France and Virgin Atlantic. Precision is the protection.
The wider risk picture supports the same discipline. RepRisk found greenwashing incidents falling for the first time in six years while the severity of incidents rose, and 249 new climate cases were filed in 2025, taking the global total past 3,600, according to the Grantham Research Institute at LSE in June 2026.
The circular marketing model
Traditional marketing follows a linear pattern: create, sell, dispose, repeat. A circular model designs every phase of production, communication and consumption to reduce waste and extend value: repurposing creative assets instead of producing more, extending product lifecycles through innovation, and encouraging reuse and participation.
A UAE luxury brand I worked with adopted a circular campaign model, reusing a substantial share of creative from previous seasons through fresh contextualisation rather than commissioning new production each season. The result was lower cost, a smaller production footprint and more consistent brand storytelling. Reusing well-made work is usually a creative gain as much as an efficiency one.
People, ESG and the region
Your employees are the first test of any sustainability position. A business that claims to care about the world and neglects its people creates a gap everyone inside it can see. Sustainable marketing starts with inclusive policies, open communication and shared purpose, and it becomes credible when it is lived rather than launched.
Purpose matters to the people you are trying to hire. Deloitte’s Global Gen Z and Millennial Survey, published 2 June 2025 from 23,482 respondents across 44 countries, found 89 per cent of Gen Z and 92 per cent of millennials describing a sense of purpose as important to job satisfaction, with around 40 per cent of both groups having turned down an assignment or an employer on ethical grounds.
On the region, be accurate about where things stand. The UAE announced its Net Zero by 2050 strategic initiative on 7 October 2021, the first Gulf state to commit, and submitted a 2035 nationally determined contribution in November 2024 targeting a 47 per cent reduction below 2019 levels, the first country in the world to lodge a 2035 target. Climate Action Tracker rates that target insufficient against the Paris goals and notes that oil, gas and power sector plans remain hard to reconcile with net zero by 2050. Both facts belong in the same sentence when you are advising a board.
Sustainability also now runs through the whole customer journey: whether the brand aligns with a buyer’s values at awareness, whether it is transparent at consideration, whether the product is responsibly made at purchase, and whether the business acts with integrity after the sale.
From campaigns to commitments
After more than 20 years in marketing leadership, my view is that sustainability is a test of intent, creativity and the willingness to be specific. The brands that pass it will be the ones whose claims hold up when someone checks.
“Purpose is not the opposite of profit. Done honestly, it is one of the most durable sources of it.”
The practical work is unglamorous: measure what you actually do, say only what you can evidence, publish the basis and the period, and get the claims reviewed before the campaign is booked rather than after a regulator asks. Building growth that lasts sits inside the growth and performance work I lead, and the trust dimension of it is covered in brand trust in the AI era.
Five takeaways
- From 27 September 2026 the EU prohibits generic green claims and bans carbon neutral claims based on offsetting.
- UK liability now extends to repeating or relying on a third party’s environmental claim, and intent is irrelevant.
- The 73 per cent willingness-to-pay figure is from 2015 and refers to millennials. Use the current evidence instead.
- Stated willingness to pay is around 10 per cent. Sustainability-marketed products often carry a 28 per cent premium.
- Measure first, claim second. The emissions data UAE law now requires is the same data a defensible claim needs.
Sources. Willingness to pay: PwC Voice of the Consumer Survey, published 15 May 2024, more than 20,000 consumers across 31 countries. Say-do gap: Bain and Company, September 2025, 14,206 consumers across eight countries including the UAE and Saudi Arabia, and Whelan and Kronthal-Sacco, NYU Stern Center for Sustainable Business, published May 2026, with GlobeScan awareness data. Margin performance: Accenture with the World Economic Forum, Shaping the Sustainable Organization, published 22 September 2021, around 4,000 companies, correlational. EU rules: Directive (EU) 2024/825 on empowering consumers for the green transition, applying from 27 September 2026. The separate EU Green Claims Directive proposal is blocked pending withdrawal announced 20 June 2025. UK: Competition and Markets Authority Green Claims Code and supply chain guidance published 22 January 2026, under the Digital Markets, Competition and Consumers Act 2024. UAE: Federal Law No. 15 of 2020 on consumer protection, and Federal Decree-Law No. 11 of 2024 on the reduction of climate change effects, in force 30 May 2025. Workforce data: Deloitte Global Gen Z and Millennial Survey, published 2 June 2025, 23,482 respondents across 44 countries. Climate targets: UAE Net Zero by 2050 initiative announced 7 October 2021, 2035 nationally determined contribution submitted November 2024, assessed by Climate Action Tracker. Greenwashing incidence: RepRisk annual greenwashing reports. Litigation volumes: Grantham Research Institute on Climate Change and the Environment, LSE, Global Trends in Climate Change Litigation 2026 Snapshot, published 25 June 2026. Emirates figures are as published by Emirates. This article is general information rather than legal advice.
Frequently asked questions
Select a question to open the answer.
What is sustainable marketing?
Sustainable marketing is the practice of growing a brand in a way that does not deplete what sustains it. It designs strategy around three pillars: the planet, meaning waste and emissions; people, meaning wellbeing and inclusion; and performance, meaning long-term profitability and trust. In 2026 it also means claims that can be evidenced, because the rules on environmental marketing have tightened.
Will consumers really pay more for sustainable products?
Some will, and by less than the industry usually claims. PwC found an average stated willingness to pay 9.7 per cent more in 2024. Bain found consumers stating up to 13 per cent while sustainability-marketed products carried an average 28 per cent premium in the market. The widely quoted 73 per cent figure is from Nielsen in 2015 and referred to millennials, not all consumers.
What changes on 27 September 2026?
Directive (EU) 2024/825 on empowering consumers for the green transition takes effect. It prohibits generic claims such as sustainable, green, eco and environmentally friendly unless excellent environmental performance is demonstrated, and it prohibits outright any carbon neutral, climate neutral or net zero claim based on offsetting. Sustainability labels need independent third-party verification, and future performance claims need time-bound targets and a published implementation plan.
What is greenwashing and how do you avoid it?
Greenwashing is claiming environmental progress without proof, and it erodes trust faster than saying nothing. Avoid it with transparency, publishing the impact with its measurement basis and period; accountability, backing claims with independent verification; and consistency, so the marketing describes what the business actually does. Precision is the protection: most rulings against brands have turned on a true fact compressed into a misleading headline.
Does UK law hold me responsible for a supplier’s green claim?
Yes. Competition and Markets Authority guidance published on 22 January 2026 extends liability to businesses that repeat, rely on or pass on a third party’s environmental claim, and intent is irrelevant. Relying on a supplier’s assurance is no longer a defence. Penalties under the Digital Markets, Competition and Consumers Act 2024 reach 10 per cent of global turnover or GBP 300,000, whichever is higher.
Do UAE businesses have to worry about green claims rules?
The UAE has no dedicated green claims regime. Environmental claims fall under Federal Law No. 15 of 2020 on consumer protection, which prohibits misleading advertisement with fines from AED 10,000 to AED 2,000,000. Separately, Federal Decree-Law No. 11 of 2024 has required emissions measurement and reporting from all entities including free zones since 30 May 2025. Any UAE business advertising into the EU or UK is caught by those regimes too.
What is the circular marketing model?
It replaces the linear create, sell, dispose, repeat pattern with one that reduces waste and extends value at every stage: repurposing creative assets, extending product lifecycles through innovation, and encouraging reuse and participation. It usually cuts cost and production footprint while keeping brand storytelling consistent.
Fractional CMO, Dubai. MSc, FCIM, CDMP.
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