Redress and enforcement

This paper shows how the EU private international law, which is not adapted to cross-border representative actions, has in fact become a barrier to such actions. We suggest several solutions to make mass claims more manageable both for claimant organisations and the courts.

Two years after BEUC denounced airlines’ widespread greenwashing to EU authorities, the situation has improved but more still needs to be done. As the Paris Air show is in full swing, BEUC encourages the European Commission and the network of consumer protection authorities (CPC-Network) to keep investigating the airlines’ practices and agree on commitments to make their marketing more trustworthy.

In June 2023, BEUC and 23 of its members from 19 countries lodged an EU-wide complaint against 17 European airlines for greenwashing. Based on a new evidence-gathering and two years after we launched our ‘Green (f)lying’ action we found that:
• Some airlines have removed or changed their climate-related marketing claims. This
appears to be a result of the actions launched by consumer groups and other civil society
organisations4 as well as of the exchanges between airlines and consumer protection
authorities.5
• However, greenwashing continues to be widespread, and some changes have been
limited (such as light changes in the wording and/or colour codes). Consumers are overall
still being faced with the false impression that they are choosing a sustainable transport
method rather than a highly polluting one.
• Airlines’ green claims continue to rely on two key arguments: As shown in our 2023
action, claims mainly misrepresent the impact of the flight through reliance on ‘offsetting’
claims and oversell the trader’s future goals and plans.
• ‘Green fares’ are increasingly popular. The airlines which are part of the Lufthansa group
registered a steady rise of such fares, which grant consumers extra miles or loyalty points.6
• Regulatory contexts are getting stricter in Europe and beyond. An increasing number of
authorities and court decisions have clarified when and how climate-related claims can be
admissible.

This document provides a summary of the dark patterns observed on the selected SHEIN websites and app between November 2024 and May 2025. The products seen in the screenshots have been randomly selected, with a variety of clothes and accessories, to show the widespread use of dark patters - irrespective of product.

The fast fashion industry uses dark patterns (manipulative techniques) to prompt consumers into buying more and more clothing. This costs them money, exposes them to harmful chemicals, and has a major environmental and societal impact. SHEIN has rapidly emerged as the most egregious example of the use of dark patterns. The following research from BEUC members highlights how consumers are being deceived by these practices into overconsumption.

BEUC – together with 25 members from 21 countries – filed a complaint today with the European Commission and European consumer protection authorities against SHEIN for its use of deceptive techniques (‘dark patterns’). These push consumers into purchasing more than originally intended and fuel the environmental and societal problems caused by the fast fashion industry.

Based on new research, including studies by BEUC members across Europe, this report reveals how deceptive techniques (‘dark patterns’) trigger unwilling spending and economic losses for consumers, fuel the circulation of unsafe clothing items across Europe, and disempower consumers in their efforts towards the green transition.

This is a joint statement by BEUC, BusinessEurope and EuroCommerce calling for a swift review of the Consumer Protection Cooperation Regulation.