Greenwashing claims are still a thing, and businesses should treat them as a legal compliance issue, not merely a public relations concern.

That point was underscored last week when Sonoma County District Attorney Carla Rodriguez announced that Tractor Supply West, LLC entered into a stipulated judgment requiring the company to pay $5,126,282.97 in civil penalties, restitution, and costs to resolve allegations involving environmental marketing, pricing, and pesticide compliance.

The case is particularly significant because it demonstrates how greenwashing claims can become intertwined with traditional consumer protection and environmental regulatory enforcement.

The Tractor Supply Case

According to the final judgment and injunction, District Attorneys from Sonoma, San Diego, Santa Cruz, Sacramento, and San Bernardino counties alleged that Tractor Supply engaged in three categories of unlawful conduct.

First, the company allegedly sold products labeled “biodegradable” in violation of California’s environmental marketing laws.

Second, it allegedly charged customers prices higher than the lowest advertised or posted price.

Third, it allegedly violated California pesticide requirements by selling pesticides without current valid licenses, failing to document pesticide sales as required, and selling restricted pesticides without the appropriate licensing.

Importantly for operators of businesses, each of these alleged violations also constituted a violation of California’s Unfair Competition Law, California Business and Professions Code § 17200 et seq. California defines unfair competition broadly to include consumer protection, even of environmental matters.

The judgment, signed by Superior Court Judge Patrick Broderick on August 5, 2026, also requires Tractor Supply to implement new policies and procedures designed to ensure future compliance.

The company cooperated with the investigation and voluntarily stopped selling pesticides until appropriate licensing was obtained after being contacted by the District Attorneys.

That cooperation, however, did not eliminate the substantial financial consequences.

“Biodegradable” Is a Legal Claim

Businesses sometimes treat words such as “biodegradable,” “recyclable,” “sustainable,” “environmentally friendly,” and “eco-friendly” as marketing language.

Regulators increasingly do not.

California has specifically regulated environmental representations for decades. Business and Professions Code § 17580 requires companies making certain environmental representations to maintain documentation supporting those claims, including information concerning environmental impacts and whether applicable claims conform to the FTC’s environmental marketing standards.

California’s statutory framework is supplemented by the federal government’s longstanding approach to environmental marketing. The Federal Trade Commission’s Green Guides caution that environmental claims must be truthful and substantiated. For example, the FTC says an unqualified degradable claim generally requires evidence that the entire product or package will completely break down within a [un]reasonably short period, defined in the Guides as one year for solid waste products.

The important compliance lesson is that the marketing department does not get a free pass because a claim came from a product manufacturer, supplier, or advertising agency. Companies need to understand what their labels and marketing materials actually communicate to a reasonable consumer and maintain the substantiation necessary to support those representations.

This Is Not Just a California Issue

The Tractor Supply matter should not be dismissed as a California peculiarity.

Federal regulators have pursued environmental marketing cases, including FTC enforcement involving allegedly unsupported biodegradable claims. The FTC has emphasized that marketers can be responsible not only for express statements but also for reasonable implied environmental claims.

California has also pursued much larger greenwashing cases. In 2023, the California Attorney General reached a settlement with Southern California Gas Company concerning allegedly misleading statements that natural gas was “renewable.” The settlement imposed penalties and prohibited similar unqualified claims.

In 2024, California sued ExxonMobil over alleged deception concerning the recyclability of plastic and alleged misleading marketing surrounding recycling. California also amended its lawsuit against major fossil-fuel companies to add allegations of continuing greenwashing concerning their environmental and climate impacts.

And in 2005, California announced a new front in the state’s ongoing battle against plastic pollution, filing suit against three of the nation’s largest plastic bag manufacturers, alleging that the companies falsely labeled  carry out bags  “recyclable” and “return to participating store for recycling,” .. despite that the bags are objectively “recyclable.”

Other jurisdictions are moving in the same direction. New York legislation introduced in the 2025 – 2026 session would expressly prohibit deceptive environmental marketing claims, including misleading claims concerning net zero emissions.  And believe it or not, we blogged, New York is Coming for Your Cheeseburger with Greenwashing Case.

The legal theory may differ from jurisdiction to jurisdiction, but the trend is unmistakable: environmental representations are increasingly being treated as regulated commercial claims.

But the response is not monolithic. In May 2026, the U.S. Court of Appeals for the Fourth Circuit partially blocked Maryland’s new greenwashing law for retail electricity suppliers, holding that the advertising restriction likely violates the First Amendment and issuing a preliminary injunction against limiting use of terms like “clean,” “green,” and “100% renewable” if the state’s specified conditions were not met.

The Compliance Lesson for Business Leaders

The Tractor Supply judgment is a reminder that environmental compliance extends beyond permits, emissions, hazardous materials, and contaminated property.

It can begin with a word on a package or marketing material.

Companies selling, leasing, or otherwise doing business with consumers should therefore inventory environmental claims appearing on:

• Product labels and packaging;
• Websites and ecommerce listings;
• Advertisements and catalogs;
• Sustainability reports;
• Social media;
• Point of sale and leasing materials; and
• Corporate sustainability communications.

For each claim, management should ask: What would a reasonable consumer understand this statement to mean, and can the company prove it?

That question should be answered before the claim reaches the marketplace, not after a District Attorney, Attorney General, FTC, or plaintiff’s lawyer begins asking questions.

The Tractor Supply judgment makes the point particularly well. What may begin as a “green” marketing claim can become an alleged violation of environmental law, consumer-protection law, unfair competition law, and related regulatory requirements, all in the same enforcement action.

Greenwashing is still a thing. Increasingly, so is greenwashing enforcement.