RIDAO

East-Asian Law Journal

Green Labels, Red Flags: Comparative Legal Pathways to Environmental Legitimacy in the European Union and the People’s Republic of China

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Abstract

This article explores how greenwashing is regulated through environmental labelling in the European Union and the People’s Republic of China. Through a comparative analysis, it contrasts the EU’s ex-post model – based on substantiation and market supervision – with China’s ex-ante architecture of sovereign certification, grounded in the ideological tenets of ecological civilization. The study reveals how each system embeds environmental legitimacy within distinct legal, institutional, and political logics, offering a broader reflection on the semiotics of sustainability and the governance of credibility in the global green transition.


open access | peer reviewed

Submitted: July 16, 2025 | Accepted: Oct. 1, 2025 | Published Dec. 19, 2025 | Language: en

Keywords GreenwashingState-led certificationPeople’s Republic of ChinaComparative LawEnvironmental claims