Greenwashing Enforcement Log
AqNova Company Information
Overview
AqNova Marketplace | Arivon Holding Corporation
ENFORCEMENT LOG
Public Transparency Record | The AqNova CLEAN Framework | Listings Removed · Badges Revoked · Vendors Suspended · Claims Found Unverified
| C COMMITMENT TO ACCOUNTABILITY | L LIVE LOG of Enforcement Actions | E EVIDENCE Standards | A AGGREGATE Transparency Statistics | N NOTIFICATION & Consumer Rights |
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| LOG OPEN April 1, 2026 Canada Commercial Launch | 8 Total Actions Apr 1 – Jun 18, 2026 | 4 Listings Removed or Suspended | 6 Badges Revoked Apr 1 – Jun 18, 2026 | 1 Vendor Terminated Apr 1 – Jun 18, 2026 | 1 Regulatory Referral Apr 1 – Jun 18, 2026 |
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| Document: Greenwashing Enforcement Log (Public) Status: LIVE — Updated on each enforcement action Log Period: April 1; 2026 — ongoing | Update Frequency: Within 5 business days of each action Maintained By: AqNova Sustainability Verification Team Regulatory Cross-Reference: Sustainability & Verification Policy §7 | Report Greenwashing: verify@aqnovamarketplace.com Consumer Rights (affected purchases): rights@aqnovamarketplace.com Full Archive: aqnovamarketplace.com/enforcement/archive |
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| This is a LIVE document. New enforcement actions are added within 5 business days of completion. This log is the public record of AqNova's enforcement actions against greenwashing; sustainability misrepresentation; and unverified environmental claims on the AqNova Marketplace platform. |
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AqNova Marketplace | Arivon Holding Corporation | EIN: 41-3210066 | Huntington Park; California; USA
Table of Contents
SECTION 1 — C — Commitment to Accountability: Why AqNova Publishes This Log .................. 3
5 Rationale Pillars: Consumer Protection · Market Deterrence · Regulatory Cooperation
Industry Accountability · Scientific/Policy Progress
What a log entry does and does not establish · Legal basis · Defamation safeguards
SECTION 2 — L — Live Log: How to Read the Enforcement Log; Entry Structure & Codes ............ 7
Reference system (AQN-GWL-YYYY-NNN) · 10-column field definitions
Vendor identification: Level 1-2 anonymized; Level 3-4 naming consideration
SECTION 3 — E — Evidence Standards: Violation Categories; Severity Levels & Action Types ...... 11
8 Violation Categories: CAT-A (False) · CAT-B (Vague) · CAT-C (Misleading Omission)
CAT-D (Irrelevant) · CAT-E (Carbon Overclaiming) · CAT-F (Cert Mark Misuse)
CAT-G (Implied Imagery) · CAT-H (Scope Misrepresentation)
4 Severity Levels (L1 Administrative/orange; L2 Negligent/gold; L3 Serious/red; L4 Fraud/dark red)
9 Action Types (Badge Revocation → Vendor Termination → Regulatory Referral)
SECTION 4 — L — LIVE ENFORCEMENT LOG (April 1, 2026 — June 18, 2026) ............................. 19
8 Log Entries (AQN-GWL-2026-001 through AQN-GWL-2026-008)
AQN-GWL-2026-004: Level 4 Named Entry — Fabricated FSC Certificate
Competition Bureau Canada Referral · 19 Consumers Notified · CAD $2,340 Refunded
SECTION 5 — A — Aggregate Transparency Statistics (April 1 — June 18, 2026) ..................... 29
8 actions · 1 termination · 1 regulatory referral · 43 consumers notified
50% of violations detected by AqNova automated monitoring (no consumer report needed)
Average closure time: 11.3 business days · Annual Transparency Report: by March 31, 2027
SECTION 6 — N — Notification & Rights: Consumer Rights When a Purchased Product Is Affected .... 33
Level 4: Full refund regardless of return window or condition · Level 3: Full refund offered
Level 2: Optional return within 30 days · Level 1: No consumer impact (administrative)
Consumer Rights by Jurisdiction: 10 jurisdictions (USA; EU; UK; Canada; Australia;
Brazil; South Africa; India; UAE/Saudi/GCC; Nigeria)
SECTION 7 — How to Report Greenwashing ...................................................................... 42
verify@aqnovamarketplace.com · 24h acknowledgment · 20BD investigation · Anonymous OK
SECTION 8 — Log Maintenance; Legal Framework & Contacts ............................................. 44
Log update frequency: 5BD · Permanent archive · Correction policy (no silent deletions)
Legal basis: EU DSA · UK OSA · EU GPSR · US First Amendment · ACCC · Competition Act
APP A — Version History & Approval Log ....................................................................... 49
| SECTION 1 | C — COMMITMENT TO ACCOUNTABILITY: WHY AQNOVA PUBLISHES THIS LOG |
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1.1 The Case for Public Disclosure of Greenwashing Enforcement
Most marketplaces that take action against greenwashing do so silently. A listing disappears; a badge vanishes — but no public record explains why. Consumers who purchased the product before the removal receive no notification. Regulators have no public evidence of the platform's enforcement activity. Other vendors have no visible deterrent. And the broader market never learns that a specific type of sustainability claim was found to be false.
AqNova operates differently. This Greenwashing Enforcement Log is our commitment to radical transparency: every enforcement action we take against a vendor for sustainability misrepresentation is recorded here; publicly; with the nature of the violation; the action taken; and the outcome. We believe this transparency serves consumers; regulators; the market; and ultimately the cause of genuine sustainability.
| Field | Detail |
|---|---|
| Consumer Protection | Consumers who have purchased a product that subsequently fails our verification process deserve to know. This log is a tool for consumers to check whether any product they have purchased has been subject to enforcement action. Every entry includes information about whether consumer notifications were sent and whether refunds are available. |
| Market Deterrence | Research consistently shows that the threat of public disclosure is a more effective deterrent to greenwashing than private enforcement. When vendors know that a sustainability misrepresentation will result in a public log entry — not just a private platform action — the incentive to misrepresent is materially reduced. We publish this log because we want vendors to know it exists. |
| Regulatory Cooperation | National regulators (FTC; EU national competent authorities; UK CMA; ACCC; Canada Competition Bureau; and others) have increasing responsibility for greenwashing enforcement. This log demonstrates to those regulators that AqNova is an active partner in enforcement — not a passive host for false claims. Where our investigations identify likely violations of national law; we make referrals to the relevant authority and record them here. |
| Industry Accountability | AqNova operates in an industry where most sustainable marketplace claims are self-regulatory. By publishing this log; we create a public standard. We invite journalists; NGOs; researchers; and regulators to review our enforcement record and hold us accountable for the quality and consistency of our decisions. If we fail to enforce against clear greenwashing; that failure will be visible. If we over-enforce unfairly; appeals and overturned decisions will be visible here. |
| Scientific and Policy Progress | The pattern of violations in this log — which types of claims are most commonly found to be false; which product categories have the most issues; which certification types are most frequently misrepresented — provides valuable data for policymakers; researchers; and standard-setters working on the next generation of sustainability regulations. |
1.2 What This Log Does and Does Not Establish
| Field | Detail |
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| What a Log Entry Establishes | A log entry records: that AqNova conducted an investigation; what AqNova found based on the evidence available to it; and what action AqNova took on the platform (badge revocation; listing removal; vendor suspension; etc.). It does not constitute a legal finding; a court judgment; or a regulatory determination. AqNova is a marketplace operator — not a court. |
| Legal Effect of Log Entries | Log entries do not constitute defamation; libel; or unfair competition claims against the named or described vendor because: (a) all entries are based on documented evidence; (b) findings are stated as AqNova's platform-level determinations; not legal judgments; (c) vendors whose appeals are upheld are identified as such in the log; (d) AqNova's Vendor Agreement specifically provides that enforcement actions may be recorded publicly. Vendor identification: Standard entries use a geographic and category reference (e.g., "Vendor [West Africa]-[Organic Skincare]"). Entries involving Level 4 (Fraudulent) violations or regulatory referrals may include the full vendor name where required by applicable law or in the interest of consumer protection. |
| What This Log Does Not Establish | This log is not: an exhaustive record of all product quality issues on the platform (product defects are handled through the returns and dispute system; not this log); a record of legal proceedings (litigation or regulatory action by third parties is not logged here unless AqNova receives a formal finding); or an admission of liability by AqNova for actions or omissions by vendors. |
| SECTION 2 | L — LIVE LOG: HOW TO READ THE ENFORCEMENT LOG; ENTRY STRUCTURE & CODES |
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2.1 Log Entry Reference System
Every entry in this log carries a unique reference number in the format: AQN-GWL-YYYY-NNN. Where: AQN = AqNova Marketplace; GWL = Greenwashing Log; YYYY = the year the action was initiated; NNN = sequential number within the year (001; 002; etc.). Example: AQN-GWL-2026-004 is the fourth enforcement action initiated in 2026.
2.2 Column Definitions — How to Read Each Field
| Field | Detail |
|---|---|
| Reference | Unique log entry reference number (AQN-GWL-YYYY-NNN). Use this reference when contacting AqNova about a specific enforcement action; submitting a consumer rights request; or citing this log in research or journalism. |
| Date Initiated | The date AqNova formally opened the investigation or enforcement action. Not the date the violation first occurred (which may be earlier and is noted in the full investigation summary; available on request for affected consumers). |
| Product Category | The product category of the affected listing(s). Where multiple product categories are involved: the primary category is shown; with the number of additional categories noted. |
| Violation Category | The type of greenwashing or sustainability misrepresentation identified. See Section 3 for full definitions of each violation category. |
| Severity Level | The severity of the identified violation; rated 1-4: Level 1 (Administrative Non-Compliance); Level 2 (Negligent Misrepresentation); Level 3 (Serious Misrepresentation); Level 4 (Fraudulent Claim). See Section 3.2 for full severity level definitions. |
| Action Taken | The enforcement action(s) AqNova took. Actions range from badge revocation through vendor termination. Multiple actions may apply. See Section 3.3 for full action type definitions. |
| Regulatory Referral | Whether AqNova referred the matter to a national regulatory authority. If yes: the authority name is shown in the full entry (in the expanded view at aqnovamarketplace.com/enforcement/log). |
| Consumer Notice | Whether AqNova sent notifications to consumers who purchased the affected product(s) during the period when the non-compliant claim or badge was displayed. Yes = notifications sent; N/A = no consumer purchases during the relevant period. |
| Status | Current status of the enforcement action: CLOSED (action complete; no appeal pending); ACTIVE (action in progress — listing/badge suspended pending investigation conclusion); UNDER REVIEW (investigation ongoing — no final action taken yet); APPEALED (vendor has appealed; action on hold pending outcome); OVERTURNED (appeal upheld; action reversed; badge or listing restored). |
| Full Summary → | Click/tap the arrow (→) in the online log to access the full investigation summary for each entry; including: specific claim found to be non-compliant; evidence relied upon; vendor response; outcome detail; consumer impact; and any regulatory referral documentation. Full summaries are available online; not reproduced in this document. |
2.3 Vendor Identification — Privacy and Transparency Balance
| Field | Detail |
|---|---|
| Standard Entries (Levels 1 and 2) | Identified by geographic region and product category (e.g., "Vendor [EU]-[Natural Cosmetics]"; "Vendor [West Africa]-[Organic Food]"). Vendor name is not published for Level 1 and 2 violations in the public log. Full details: available to the affected consumer upon request with order documentation; and to regulatory authorities upon lawful request. |
| Serious and Fraudulent Violations (Levels 3 and 4) | Where a Level 3 or Level 4 violation has been substantiated: AqNova considers whether to publish the vendor name based on: (a) whether the vendor has been permitted a reasonable opportunity to appeal; (b) whether publication is necessary for effective consumer protection; (c) whether a regulatory referral has been made and the authority has consented to or requested publication; (d) any applicable data protection or defamation law considerations. Named entries are marked [NAMED] in the log. |
| Overturned Entries | Where an enforcement action is overturned on appeal: the log entry is updated to reflect the OVERTURNED status; the action taken is noted as reversed; and the vendor is identified (at the vendor's election) as having had the action overturned in their favor. AqNova does not delete overturned entries — the full history remains visible. |
| SECTION 3 | E — EVIDENCE STANDARDS: VIOLATION CATEGORIES; SEVERITY LEVELS & ACTION TYPES |
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3.1 Greenwashing Violation Categories (Used in Log Entries)
| Code | Category | Definition | Key Regulatory Framework |
|---|---|---|---|
| CAT-A | False Claim | A sustainability claim with no factual basis whatsoever — e.g., claiming a product holds an organic certification it does not hold; displaying a certification logo the product is not certified under. CAT-A violations are the most serious category of greenwashing and may constitute criminal fraud in some jurisdictions. | FTC Green Guides §260.4; UK CMA Green Claims Code Principle 1; EU Empowering Consumers Directive (ECD 2024/825/EU); Australian Consumer Law §29; Consumer Defense Code Brazil §37. |
| CAT-B | Vague / Unsubstantiated Claim | A sustainability claim so general that it conveys an environmental benefit but cannot be substantiated — e.g., "eco-friendly"; "green"; "sustainable"; "natural"; "planet-friendly"; "environmentally responsible" — without qualification or evidence. The claim may be directionally true in some sense but cannot be verified or falsified. | FTC Green Guides §260.4(b); UK CMA Code Principle 2; EU ECD Annex I (prohibited commercial practices list — "eco-label not granted by official scheme"); ACCC Environmental Claims Guidance 2023 Principle 3; India ASCI Guidelines January 2023. |
| CAT-C | Misleading Omission | A sustainability claim that is true in isolation but creates a false overall impression by omitting material negative information — e.g., "organic cotton" shirt that uses toxic dyes; "recycled packaging" for a product containing SVHC substances; "carbon neutral delivery" for a product with a very high manufacturing footprint. The claim is technically accurate but misleads the consumer about the overall environmental impact. | FTC Green Guides §260.3(b) (qualifications); UK CMA Code Principle 3; EU ECD Art.7 (misleading omissions); ACCC Principle 4 (not mislead by omission); Canadian Competition Act §74.01(1)(b). |
| CAT-D | Irrelevant Claim | Claiming compliance with a standard that is legally mandated — creating a false impression that the product has done something beyond the legal minimum when in fact all products in the category must meet that standard — e.g., "CFC-free" (global ban since 1989 under Montreal Protocol); "no animal testing" in jurisdictions where cosmetic animal testing is already prohibited by law. | FTC Green Guides §260.4(d) (claims relevant only if meaningful); UK CMA Code Principle 2 (not create false impression by omission of relevance); EU ECD Annex I item 4 (claim that consumer has already legal right as such). |
| CAT-E | Carbon Claim Overclaiming | Claiming carbon neutrality; net zero; climate positive; or similar climate-related status: (a) based solely on purchase of carbon offsets without genuine emission reduction; (b) without third-party verification; (c) using outdated or unrepresentative lifecycle data; (d) based on unverified offset projects that cannot demonstrate permanence; additionality; or vintage requirements. | EU ECD (carbon neutrality via offsets specifically prohibited as misleading); UK ASA/CMA guidance on carbon claims (2022-2023); ACCC Environmental Claims Guidance 2023 Principles 5-6 (specific carbon guidance); FTC Green Guides review proposals 2023; ISO 14067; PAS 2060. |
| CAT-F | Certification Mark Misuse | Using; displaying; or referencing a sustainability certification mark; logo; or label on products; packaging; or marketing materials where: (a) the product is not certified under that scheme; (b) the certification has expired; (c) the certification covers the company but not the specific product; (d) the certification was for a different product variant or production run than the one being sold. | FTC Green Guides §260.6 (third-party certification); UK Intellectual Property Act 1994 (certification trade marks); EU ECD Annex I item 2 (display of quality mark without certification). |
| CAT-G | Implied Environmental Imagery | Using design elements — green colors; nature imagery; leaf icons; earth imagery; sustainability-associated language ("clean"; "pure"; "natural") — in a way designed to create a false overall impression of environmental benefit without making any explicit verifiable claim. The visual impression is the misrepresentation. | EU UCPD Art.6 (misleading commercial practices including presentation); UK Consumer Protection from Unfair Trading Regs 2008 Reg.5; FTC Green Guides §260.3 (context of claim); ACCC Principle 2 (overall impression counts). |
| CAT-H | Scope Misrepresentation | Accurately describing a certification that exists but misrepresenting its scope — e.g., claiming a product is "FSC certified" when only the outer box is FSC certified (not the product inside); claiming "organic" certification that covers only one ingredient of many; claiming B Corp certification covers a product division that is not within the certified legal entity. | FTC Green Guides §260.4(a) (certifications that do not qualify all components); UK CMA Code Principle 2; EU Green Claims Directive COM(2023) 166 (scope requirements). |
3.2 Severity Levels — How AqNova Assesses Seriousness of Violations
| Level | Name | Definition | Typical Actions |
|---|---|---|---|
| LEVEL 1 | Administrative Non-Compliance | Certificate expiry without renewal; failure to update AqNova when certification lapses; administrative documentation gaps where the underlying certification is genuine. No indication of deliberate misrepresentation; likely oversight or administrative failure. | Badge suspension pending renewal. Vendor warning issued. Cure period provided (30 days standard). Badge restored on renewal submission. No public naming. |
| LEVEL 2 | Negligent Misrepresentation | Misleading claim where the vendor lacked the requisite evidence at the time of listing — but where the misrepresentation appears to result from negligence or inadequate due diligence rather than deliberate deception. Includes CAT-B (vague claims); CAT-D (irrelevant claims); CAT-G (implied imagery without accompanying verified claims); and CAT-C (misleading omissions that appear inadvertent). | Badge revocation. Listing suspension (30 days) or amendment. Vendor warning with corrective action requirements. Enhanced monitoring for 6 months. Anonymized public log entry. |
| LEVEL 3 | Serious Misrepresentation | Deliberate; or recklessly indifferent; misrepresentation of a sustainability claim where the vendor knew or ought to have known the claim was not supported by the evidence. Includes persistent CAT-B; CAT-C where the omission was clearly material; CAT-E (carbon overclaiming); CAT-F (certification mark misuse); CAT-H (scope misrepresentation where scope limitation was obvious). Consumer harm is likely; meaningful; or has occurred. | Badge revocation (all badges). Listing removal. Vendor suspension (minimum 90 days). Consumer notifications issued. Consideration of regulatory referral. Possible public naming. Enhanced scrutiny on reinstatement. |
| LEVEL 4 | Fraudulent Claim | Fabricated sustainability claim with no factual basis — deliberate deception of consumers. Includes CAT-A (false claim: no certification exists; fabricated certificate numbers; forged certification documents); systematic or large-scale CAT-F (certification mark misuse across multiple product lines with no good-faith error); and cases where the vendor has provided false information to AqNova during the verification process. | Immediate permanent account termination. All listings removed. All payouts held pending investigation. Consumer notifications mandatory. Regulatory referral mandatory. Public naming. Referral to: FTC; UK CMA; EU authorities; ACCC; Canada Competition Bureau; or relevant national authority based on vendor location and consumer impact. |
3.3 Action Types — What Each Action Means for Consumers
| Field | Detail |
|---|---|
| Badge Revocation Only | The sustainability badge(s) in question are removed from the product listing. The listing itself remains active. Consumers can continue to purchase the product — but the sustainability claim is no longer displayed. Consumer notifications: not issued unless the violation was Level 3 or 4. |
| Listing Flag / Claim Amendment | The listing remains active but is modified to remove or qualify the non-compliant claim. A "Claim Under Review" notice may be displayed. Consumer notifications: not standard; issued if the flag follows a consumer report. |
| Listing Suspension (Temporary) | The product listing is suspended from the platform. No new orders can be placed. Pending orders (already placed before suspension): fulfilled normally. Duration: until investigation concludes and/or vendor completes corrective action. Vendor may appeal. Consumer notifications: issued to consumers who purchased in the 30 days before suspension. |
| Listing Removal (Permanent) | The product listing is permanently removed from the platform. The vendor may re-list the product only after demonstrating full compliance through the verification process — subject to AqNova's discretion. Consumer notifications: issued to all consumers who purchased the product while the non-compliant claim was displayed. |
| Vendor Warning (Formal) | A formal written warning issued to the vendor — recorded in the vendor's compliance record on the platform. Does not restrict the vendor's ability to list or sell. Triggers enhanced monitoring for the subsequent 6-month period. |
| Vendor Probation | The vendor's account is placed on probation: new listings require pre-approval by AqNova's verification team before going live; all existing listings are subject to enhanced monitoring; the vendor receives reduced customer service priority pending probation completion. Standard probation period: 6 months. |
| Vendor Suspension (Temporary) | The vendor's account is suspended: all listings are deactivated; no new orders can be placed; pending payouts are held. The vendor may appeal. Standard suspension duration: 90 days for first Level 3 offence; 6 months for subsequent offences. |
| Vendor Termination (Permanent) | The vendor's account is permanently terminated. All listings removed. Pending payouts released (net of any refund obligations) within 90 days. No reinstatement pathway. Referral to relevant authorities where the violation constitutes a criminal act or regulatory violation. |
| Regulatory Referral | AqNova refers the matter to the relevant national or international regulatory authority — providing all evidence gathered in the investigation. AqNova cooperates fully with any subsequent regulatory investigation. The referral is recorded in this log and the relevant authority is identified in the full online entry. AqNova does not comment on regulatory investigations in progress beyond confirming the referral. |
| SECTION 4 | L — LIVE LOG: ACTIVE ENFORCEMENT LOG — APRIL 1, 2026 TO PRESENT |
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| This log covers the period from April 1, 2026 (AqNova's Canadian commercial launch date) to the current effective date of this document. New entries are added within 5 business days of enforcement action completion. Click any entry reference (→) in the online version of this log to access the full investigation summary. This document version covers actions through June 18, 2026. |
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4.1 How to Check If a Product You Bought Is Affected
To determine if a product you purchased has been subject to enforcement action: (1) Find your order reference number in Account → Orders. (2) Visit aqnovamarketplace.com/enforcement/check and enter your order reference number. (3) The system will confirm whether any product in your order is the subject of a current or historical enforcement action; and whether consumer notifications were sent to your account.
| Reference AQN-GWL-YYYY-NNN | Date Initiated | Product Category | Violation Category | Severity Level | Action Taken | Regulatory Referral | Consumer Notice | Status | Full Summary |
|---|---|---|---|---|---|---|---|---|---|
| AQN-GWL-2026-001 | Apr 3, 2026 | Organic Personal Care | CAT-F: Cert Mark Misuse — displayed Leaping Bunny logo without valid certification (certification expired Feb 2026; vendor failed to notify AqNova) | L1 ADMIN | Badge Revocation (Cruelty-Free badge). Vendor Warning. 30-day cure period. | None | N/A | ● CLOSED | → |
| AQN-GWL-2026-002 | Apr 11, 2026 | Sustainable Textiles | CAT-B: Vague Unsubstantiated Claim — product listed as "100% eco-sustainable fabric" with no certification or supporting evidence beyond vendor self-declaration | L2 NEGLIGENT | Badge Revocation (Sustainability badge removed). Listing Amendment (vague claim removed). Vendor Warning. 6-month enhanced monitoring. | None | No (purchased pre-launch period) | ● CLOSED | → |
| AQN-GWL-2026-003 | Apr 18, 2026 | Organic Food & Beverages | CAT-E: Carbon Claim Overclaiming — vendor claimed "carbon neutral production" based solely on purchase of unverified offset credits; no emission reduction activities documented; no PAS 2060 or equivalent verification | L2 NEGLIGENT | Badge Revocation (Carbon Neutral badge). Listing Amendment. Vendor Warning. Required to remove claim and reapply with PAS 2060-verified carbon neutral claim only. | None | Yes (4 consumers notified) | ● CLOSED | → |
| AQN-GWL-2026-004 | Apr 25, 2026 | Sustainable Home & Living | CAT-A: False Claim — vendor claimed FSC certification for bamboo home products; AqNova verification against FSC certificate database (info.fsc.org) revealed no valid FSC certificate in vendor's name or for the claimed supplier; certificate number submitted was invalid [NAMED — Level 4] | L4 FRAUD | Badge Revocation (all badges). Listing Removal (permanent — 3 listings). Vendor Termination. Consumer notifications mandatory. Regulatory Referral: Competition Bureau Canada (false representation of certification). | Competition Bureau Canada | Yes (19 consumers notified; full refunds offered) | ● CLOSED | → |
| AQN-GWL-2026-005 | May 7, 2026 | Clean Beauty & Skincare | CAT-H: Scope Misrepresentation — COSMOS Organic certification held for the company's product line A; displayed as certification for product line B which was not within the certified scope; 2 product listings affected | L2 NEGLIGENT | Badges revoked from 2 non-compliant listings. Remaining listings (certified scope) unaffected. Vendor Warning. Vendor required to submit revised scope documentation within 14 days. | None | Yes (8 consumers notified) | ● CLOSED | → |
| AQN-GWL-2026-006 | May 14, 2026 | Eco-Friendly Apparel | CAT-C: Misleading Omission — "Made from 100% recycled plastic bottles" claim omitted that the dyeing process used SVHC (Substances of Very High Concern) restricted under REACH; creating false overall sustainability impression | L3 SERIOUS | Badge Revocation (Recycled & Circular badge; Clean Chemistry badge not awarded). Listing Suspension (60 days). Vendor Probation (6 months). Consumer notifications issued. | None (REACH compliance referral to EU authority under review) | Yes (12 consumers notified; return option offered) | ◉ ACTIVE | → |
| AQN-GWL-2026-007 | Jun 2, 2026 | Organic Food & Beverages | CAT-D: Irrelevant Claim — vendor marketed packaged food product as "hormone-free" in markets (Canada; EU) where use of growth hormones in food production is already prohibited by law; creating false impression of special achievement | L1 ADMIN | Badge flagged. Listing Amendment required (misleading attribute removed). Vendor notified. 14-day cure period. | None | N/A | ● CLOSED | → |
| AQN-GWL-2026-008 | Jun 10, 2026 | Sustainable Personal Care | UNDER INVESTIGATION — Consumer report received June 10; 2026 alleging that "Fair Trade Certified" claim cannot be verified in Fairtrade International (FLOCERT) database for the claimed product. AqNova has requested vendor documentation. Vendor has 5 business days to respond (deadline: June 17; 2026). Listing's Fair Trade badge temporarily suspended pending outcome. | L1 ADMIN | Fair Trade Badge Suspended (temporary; pending investigation outcome). No other action yet. | TBD | TBD | ◎ UNDER REVIEW | → |
| Full investigation summaries for all closed entries are available at aqnovamarketplace.com/enforcement/log. Consumers who purchased any product subject to a CLOSED entry with consumer notifications: contact rights@aqnovamarketplace.com with your order reference number to request return/refund options. |
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4.2 Log Entry AQN-GWL-2026-004 — Full Summary (Level 4 Named Entry)
| This section reproduces the full public summary for entry AQN-GWL-2026-004 — the only Level 4 (Fraudulent Claim) entry in the log to date. Level 4 entries include full vendor identification and are published in full consistent with AqNova's public disclosure policy for serious violations. All other entries are summarized by geographic region and category code in the main log above; with full investigation summaries available to affected consumers on request. |
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| AQN-GWL-2026-004 | LEVEL 4: FRAUDULENT CLAIM | [NAMED] Action Initiated: April 25, 2026 | Action Closed: May 12, 2026 | Status: CLOSED Vendor: [Name withheld at legal counsel recommendation pending Competition Bureau Canada investigation — will be published upon conclusion of regulatory proceedings. Geographic Region: Ontario, Canada. Product Category: Sustainable Home & Living — Bamboo products.] Alleged Violation: Three product listings claimed FSC (Forest Stewardship Council) certification for bamboo furniture and homeware products. Vendor submitted a certificate number (FSC-C######) in the AqNova Certification Registry onboarding process. Evidence of Violation: Triggered by a consumer report (received April 24, 2026) from a purchaser who independently checked the submitted certificate number against the FSC public certificate database (info.fsc.org) and found no matching record. AqNova's verification team conducted independent verification on April 25: the submitted certificate number does not exist in the FSC certificate database; neither the vendor entity name nor the vendor's stated supplier name appears in the FSC certified entities database. The FSC logo displayed on product images was not accompanied by any valid FSC license code. Vendor Response: Vendor was notified April 25 and given 48 hours to provide valid certification documentation. Vendor did not respond within the 48-hour window. Vendor subsequently submitted a document purporting to be an FSC certificate on April 28; AqNova's verification team assessed this document and determined it was inconsistent with FSC's standard certificate format and contained anomalies suggesting the document was not an authentic FSC-issued certificate. AqNova notified FSC directly — FSC confirmed no certificate had been issued to the vendor or vendor's claimed supplier. Actions Taken: (1) All three product listings permanently removed (April 25 — immediate suspension; April 28 — permanent removal confirmed). (2) Vendor account permanently terminated (May 2, 2026). (3) All pending payouts held (payout reserve: CAD $2,340; released to consumers via refund). (4) Consumer notification issued to all 19 consumers who purchased affected products. (5) Full refunds processed (May 8, 2026). (6) Matter referred to Competition Bureau Canada (May 12, 2026) as potential violation of the Competition Act (false or misleading representation — Part VI). AqNova has provided all investigation evidence to the Bureau. Consumer Impact: 19 consumers purchased affected products between the vendor's listing activation date and the investigation opening date. All 19 were notified by email on April 28, 2026. 17 of 19 requested full refunds — processed May 8, 2026. 2 consumers elected to retain purchased products. All consumers were provided with the investigation reference and the Competition Bureau Canada referral information. Regulatory Status: Referral to Competition Bureau Canada confirmed May 12, 2026 (reference: [Competition Bureau case reference to be inserted when assigned]). AqNova is cooperating with the Bureau's investigation. No further comment on ongoing regulatory proceedings. |
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| SECTION 5 | A — AGGREGATE TRANSPARENCY STATISTICS: ENFORCEMENT METRICS & TRENDS |
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5.1 Enforcement Statistics — April 1 to June 18, 2026
| Metric | Value | Context |
|---|---|---|
| Total Enforcement Actions Initiated | 8 | Covers all investigation openings from platform commercial launch (April 1, 2026) through June 18, 2026. |
| By Severity Level | Level 1: 2 actions (25%) | Level 2: 3 actions (37.5%) | Level 3: 1 action (12.5%) | Level 4: 1 action (12.5%) | Under Investigation: 1 (12.5%) | Severity distribution reflects a mix of administrative non-compliance (typical in early platform operation) and substantive misrepresentation. |
| By Violation Category | CAT-A: 1 (False Claim) | CAT-B: 1 (Vague) | CAT-C: 1 (Misleading Omission) | CAT-D: 1 (Irrelevant) | CAT-E: 1 (Carbon Overclaiming) | CAT-F: 1 (Cert Mark Misuse) | CAT-G: 0 | CAT-H: 1 (Scope Misrepresentation) | Under Investigation: 1 | CAT-F (Certification Mark Misuse) and CAT-H (Scope Misrepresentation) are the most common categories in the early platform period — consistent with industry data showing that certification documentation errors are frequent in the early stages of marketplace compliance. |
| By Product Category | Organic Food & Beverages: 2 | Sustainable Textiles/Apparel: 2 | Organic Personal Care: 1 | Clean Beauty & Skincare: 1 | Sustainable Home & Living: 1 | Sustainable Personal Care: 1 | Food and apparel categories have the highest action count — consistent with these being the product categories with the most complex and varied certification landscapes globally. |
| Actions Closed vs. Open | Closed: 7 (87.5%) | Active/Under Review: 1 (12.5%) | Overturned on Appeal: 0 | High close rate in early period reflects predominantly clear-cut cases. AqNova expects the proportion of complex cases requiring longer investigation to increase as platform volume grows. |
| Vendor Outcomes | Badge Revocation Only: 4 | Listing Suspension: 1 | Listing Removal: 1 | Vendor Warning: 6 | Vendor Termination: 1 | Regulatory Referral: 1 | One vendor termination and one regulatory referral in the first 2.5 months of operation. |
| Consumer Impact | Consumers notified: 43 across 4 closed actions | Full refunds processed: 26 | Refund value: CAD $2,340 + EUR €1,820 | Consumers who elected to retain product: 17 | All affected consumers were notified within 24 hours of enforcement action completion. |
| Investigation Source | Consumer Reports: 2 (25%) | AqNova Automated Monitoring: 4 (50%) | AqNova Periodic Re-Verification: 1 (12.5%) | Certification Body Alert: 1 (12.5%) | Automated monitoring systems (certificate expiry tracking; NLP listing content review) identified 50% of violations without a consumer report — demonstrating the value of proactive monitoring. |
| Average Time to Close | Level 1: 8 business days | Level 2: 14 business days | Level 3: Active | Level 4: 12 business days | Average all closed: 11.3 business days | Level 4 cases closed faster than Level 2/3 because the evidence was unambiguous (fabricated certificate vs. ambiguous interpretation of scope or omission). |
5.2 Annual Sustainability Transparency Report Reference
AqNova publishes a comprehensive Annual Sustainability Transparency Report by March 31 of each calendar year covering the prior calendar year's enforcement activity. The Annual Report includes: full enforcement statistics; breakdown by violation category; product category; vendor geographic region; severity level; consumer impact; regulatory referrals; and AqNova's own sustainability performance metrics (carbon; packaging; DHL GoGreen). The first Annual Report will cover the period April 1, 2026 — December 31, 2026; published by March 31, 2027. Available at: aqnovamarketplace.com/sustainability/report.
| SECTION 6 | N — NOTIFICATION & RIGHTS: CONSUMER RIGHTS WHEN A PURCHASED PRODUCT IS AFFECTED |
|---|
6.1 Your Rights If a Product You Purchased Is Subject to Enforcement Action
If AqNova issues a consumer notification for a product you have purchased — because AqNova has found that the sustainability claim displayed when you purchased was false; misleading; or unverified — you have rights. These rights exist in addition to; and independently of; AqNova's enforcement action against the vendor. AqNova proactively notifies affected consumers; but if you believe you purchased a product subject to an enforcement action and have not received notification: contact rights@aqnovamarketplace.co.
| Field | Detail |
|---|---|
| Right to Be Notified | AqNova notifies consumers by email (to the registered account email address) within 24 hours of completing an enforcement action that involves a consumer-impacting sustainability misrepresentation. The notification: identifies the specific product; describes the nature of the violation found; and explains your options. |
| Right to Return and Full Refund (Level 3 and 4 violations) | For Level 3 (Serious Misrepresentation) and Level 4 (Fraudulent Claim) enforcement actions: all consumers who purchased the affected product during the period when the non-compliant claim was displayed are entitled to a full refund — regardless of whether: (a) the product itself is defective (it may not be); (b) the standard 30-day return window has passed; (c) you have used the product; or (d) the product is unsealed. The entitlement is based on the misrepresentation of sustainability attributes — not product quality. |
| Right to Return Option (Level 2 violations) | For Level 2 (Negligent Misrepresentation) enforcement actions: AqNova offers consumers an optional return and full refund within 30 days of the consumer notification date. This return right is in addition to any statutory return rights applicable in your jurisdiction. |
| No Consumer Right to Return (Level 1 violations) | Level 1 violations (administrative certificate expiry) typically do not result in consumer notifications or return offers — because the underlying certification was genuine and the product meets its claimed standards; the issue was an administrative failure to renew paperwork. AqNova treats Level 1 violations as a documentation compliance matter; not a consumer protection matter. |
| Rights Independent of AqNova Action | Your statutory consumer rights against the Vendor under applicable law are independent of AqNova's enforcement action. Depending on your jurisdiction; you may have rights under: US state consumer protection law (misrepresentation of product attributes); EU Consumer Rights Directive and Sale of Goods Directive (goods not conforming to description); UK Consumer Rights Act 2015 (information about goods that is incorrect and becomes a term of contract); Australian Consumer Law (goods not as described — statutory guarantee); Brazil CDC (misleading advertising). AqNova's enforcement action provides evidence to support your claim but does not replace your right to pursue the Vendor directly. |
6.2 Consumer Rights by Jurisdiction — Greenwashing Misrepresentation
| Jurisdiction | Applicable Law | Consumer Rights | Enforcement Channel |
|---|---|---|---|
| USA (Federal + State) | FTC Act §5; state consumer protection statutes (UDAP laws in all 50 states); California Consumers Legal Remedies Act (CLRA); California False Advertising Law (FAL); NY General Business Law §349-350. | Right to bring private action for damages in cases of material misrepresentation. California: statutory damages $1,000 per violation plus attorney fees (CLRA). FTC may seek redress on your behalf. Class action possible under applicable state law. | FTC (ftc.gov/complaint); state AG offices; private attorney for CLRA/state UDAP claims. |
| EU (27 Member States) | Consumer Rights Directive 2011/83/EU; EU Sale of Goods Directive 2019/771; EU Unfair Commercial Practices Directive 2005/29/EC; EU Empowering Consumers Directive 2024/825/EU (effective 2026). | Right to remedies for goods not conforming to pre-contractual information; right to withdrawal (14 days) for distance contracts; right to bring unfair commercial practices complaints to national authority. | National consumer protection authority; national courts; ECC Network (eccnet.eu). |
| United Kingdom | Consumer Rights Act 2015; Consumer Contracts Regulations 2013; Consumer Protection from Unfair Trading Regulations 2008. | Pre-contractual information about sustainability attributes that is incorrect becomes a term of the contract. Right to remedy: price reduction; repair; replacement; full refund where breach is material. 14-day right of withdrawal for distance contracts. | Competition and Markets Authority (gov.uk/cma); Trading Standards; courts of England and Wales. |
| Canada | Consumer Protection Acts (provincial); Competition Act Part VI (false representations). | Right to rescind contract based on material false representation; right to damages. Competition Bureau may pursue vendor for false representations affecting consumers broadly. | Provincial consumer protection offices; Competition Bureau (competition.bureau.gc.ca); courts. |
| Australia | Australian Consumer Law (ACL) — Schedule 2 CCA; Consumer Guarantees (§§54-64); Misleading or Deceptive Conduct (§18). | Consumer guarantee that goods match description is statutory and cannot be excluded. Full refund right for major failures (goods are not what described). Private right of action in Federal Circuit Court. Statutory cause of action for misleading conduct — no need to prove intention. | ACCC (accc.gov.au); state and territory consumer protection agencies; Federal Circuit Court. |
| Brazil | Código de Defesa do Consumidor (CDC) Arts. 12; 18; 30; 35; 37. | Right to terminate contract; demand product replacement; or claim damages for misleading advertising under CDC. Art. 30: advertising claims are binding on the vendor. Class action available through consumer associations and Ministério Público. | PROCON (procon.sp.gov.br or local equivalent); SENACON (consumidor.gov.br); courts. |
| South Africa | Consumer Protection Act 2008 §§29; 41; 55-56. | Right to accurate product labeling (§29); prohibition on misleading representation (§41); implied warranty of quality (§55). Right to return within 6 months of delivery. | National Consumer Commission (thencc.gov.za); National Consumer Tribunal; courts. |
| India | Consumer Protection Act 2019; Advertising Standards Council of India (ASCI) complaints mechanism. | Right to file consumer complaint with District Consumer Disputes Redressal Commission (DCDRC); right to seek compensation for misleading advertising; class action through consumer organizations. | Consumer courts (District; State; National); ASCI (ascionline.org); CCPA. |
| UAE; Saudi Arabia; GCC | UAE Consumer Protection Law No.15/2020; Saudi Consumer Protection Law; GCC consumer frameworks. | Right to accurate product representation; right to return goods not as described. Ministry of Economy (UAE) and equivalent bodies handle consumer complaints. | UAE Ministry of Economy (economy.gov.ae); Saudi General Directorate of Consumer Protection. |
| Nigeria | Federal Competition and Consumer Protection Act 2018 (FCCPA). | Right to accurate and complete product information; right to compensation for false product claims. Consumer Business Protection Commission handles complaints. | CBPC (cbpc.gov.ng); Federal High Court. |
| SECTIONS 7-8 & APPENDICES | HOW TO REPORT; GLOBAL REGULATORY FRAMEWORK; LOG MAINTENANCE & VERSION HISTORY |
|---|
7. How to Submit a Greenwashing Report — Consumer and Third-Party
| Field | Detail |
|---|---|
| Who Can Report | Anyone: consumers; competing businesses; journalists; NGOs; academics; certification bodies; or regulatory authorities. Reports do not need to be from purchasers of the specific product — they can be from anyone who observes what they believe is a sustainability misrepresentation on the AqNova platform. |
| Reporting Channels | Primary: verify@aqnovamarketplace.com | Subject: "Greenwashing Report — [Product Name] — [AqNova Product ID if known]." Online form: aqnovamarketplace.com/sustainability/report. From any product listing: "Report" button → "Sustainability Claim Concern." Phone: available on request via email. |
| What to Include | (1) The specific product (URL; product name; AqNova product ID if visible). (2) The specific claim believed to be misleading or false. (3) Evidence or basis for the concern (e.g., "I checked the Leaping Bunny database at leapingbunny.org and this vendor is not listed"). (4) Your contact information (optional but enables us to notify you of the outcome). |
| Investigation Timeline | 24h: acknowledgment of report. 3 business days: initial listing review. 5 business days: vendor notification. 20 business days: full investigation completion. 5 business days post-investigation: reporting party notification of outcome. Complex cases: up to 40 business days. |
| Anonymous Reports | Anonymous reports are investigated on the same basis as identified reports. Anonymous reporters do not receive outcome notifications. AqNova does not share reporter identity with the vendor under investigation. |
| Bad Faith Reports | Reports submitted to harm a competitor without factual basis: actionable under AqNova's Terms of Service. AqNova may restrict or terminate accounts used to file bad-faith reports. Deliberate false reports that cause vendor harm: may give rise to civil liability for the reporter. |
8. Log Maintenance; Global Regulatory Framework for Public Disclosure & Contacts
| Field | Detail |
|---|---|
| Log Update Frequency | New entries are added within 5 business days of each enforcement action's completion. Status changes (e.g., UNDER REVIEW → CLOSED; ACTIVE → APPEALED) are updated within 24 hours. The "Log Period" date at the top of this document is updated on each revision. |
| Archive of Past Entries | All enforcement actions; including those older than 12 months; remain in the public log permanently. There is no expiry of log entries — consistent with the principle that the historical enforcement record should remain publicly accessible. Entries are archived at aqnovamarketplace.com/enforcement/archive. Archive entries include the full investigation summary. |
| Log Accuracy and Corrections | If AqNova determines that a log entry contains a factual error: the entry is corrected with a timestamped note indicating the correction; the original text is preserved (struck through) alongside the corrected text; and a brief explanation of the correction is added. No entry is silently deleted or modified without a correction note. Overturned entries: marked OVERTURNED; the reversal reason is noted; the original entry remains visible. |
| Legal Basis for Public Disclosure | Legal frameworks supporting AqNova's public disclosure of enforcement actions: EU Digital Services Act (Art. 17 — statement of reasons for content moderation; Art. 15 — transparency reporting); UK Online Safety Act 2023 (transparency obligations); EU GPSR 2023/988 (public notification of product safety enforcement — AqNova extends the GPSR model to sustainability enforcement); US First Amendment (truthful statements of fact about business conduct are protected speech); Australian Competition and Consumer Act (ACCC publishes enforcement outcomes publicly — AqNova adopts the same standard voluntarily); Canada Competition Act (Competition Bureau publishes investigation outcomes — AqNova adopts the same standard). |
| Defamation Safeguards | All log entries are: (a) based on documented evidence; (b) stated as AqNova's platform-level determinations; not legal judgments; (c) subject to the vendor's right to appeal and have outcomes corrected; (d) anonymized by default for Levels 1-2; with naming reserved for Levels 3-4 following a deliberate public interest assessment. AqNova maintains detailed investigation files for all entries available to courts and regulatory authorities. AqNova's legal team reviews all Level 3-4 entries before publication. |
| GDPR / Data Privacy Considerations for Named Entries | For entries where a vendor's legal entity name (not individual name) is published: AqNova relies on the lawful basis of legitimate interests under GDPR Art.6(1)(f) (public interest in transparent sustainability enforcement; consumer protection) and statutory obligation under applicable platform governance regulations. Individual person names are not published in enforcement log entries. For entries involving sole trader vendors where the trader's name is the same as the business name: legal advice is obtained on a case-by-case basis before publication. |
| Contact Type | Contact Details |
|---|---|
| Report Greenwashing | verify@aqnovamarketplace.com | aqnovamarketplace.com/sustainability/report |
| Consumer Rights (Affected Purchases) | rights@aqnovamarketplace.com | Account → Orders → "Was my purchase affected?" |
| Full Investigation Summaries (Consumers) | aqnovamarketplace.com/enforcement/log (online version with expandable entries) |
| Enforcement Archive (Historical Entries) | aqnovamarketplace.com/enforcement/archive |
| Order Impact Checker | aqnovamarketplace.com/enforcement/check (enter your order reference number) |
| Annual Sustainability Report | aqnovamarketplace.com/sustainability/report (published by March 31 annually) |
| Competition Bureau Canada (AQN-GWL-2026-004 Referral) | competition.bureau.gc.ca |
| Legal Notices and Vendor Appeals | legal@aqnovamarketplace.com | verify@aqnovamarketplace.com |
| Sustainability & Verification Policy (Full Policy) | aqnovamarketplace.com/sustainability/policy |
| Postal — Legal Department | AqNova Marketplace / Arivon Holding Corporation; Huntington Park; California; USA |
Appendix A — Version History & Approval Log
| Version | Date | Summary | Approved By |
|---|---|---|---|
| 1.0 | June 2026 | Initial release. AqNova CLEAN Framework (5 principles: Commitment to Accountability; Live Log of Enforcement Actions; Evidence Standards; Aggregate Transparency Statistics; Notification and Consumer Rights). Section 1: Why we publish — 5 rationale pillars (consumer protection; market deterrence; regulatory cooperation; industry accountability; scientific and policy progress); what a log entry does and does not establish; legal basis of entries vs. court findings; defamation protections. Section 2: Log Entry Reference System (AQN-GWL-YYYY-NNN format); 10-column log structure explained; vendor identification privacy framework (Level 1-2 anonymized; Level 3-4 consideration for naming; overturned entries retained). Section 3: 8 Violation Categories (CAT-A through CAT-H) each with definition and key regulatory framework; 4 Severity Levels table (Level 1: Administrative/orange; Level 2: Negligent/gold; Level 3: Serious/red; Level 4: Fraudulent/dark red) with definition; typical actions; 9 Action Types with consumer impact description (Badge Revocation; Listing Flag; Listing Suspension; Listing Removal; Vendor Warning; Vendor Probation; Vendor Suspension; Vendor Termination; Regulatory Referral). Section 4: Live Enforcement Log — 8 entries (April 1-June 18, 2026): AQN-GWL-2026-001 (Level 1 — Cert Mark Misuse; Leaping Bunny expired; CLOSED); AQN-GWL-2026-002 (Level 2 — Vague Claim; eco-sustainable fabric; CLOSED); AQN-GWL-2026-003 (Level 2 — Carbon Overclaiming; unverified offsets-only claim; CLOSED; 4 consumers notified); AQN-GWL-2026-004 (Level 4 — FALSE CLAIM; fabricated FSC certificate; VENDOR TERMINATED; Competition Bureau Canada referral; 19 consumers notified; CAD $2,340 refunded + EUR €1,820; CLOSED); AQN-GWL-2026-005 (Level 2 — Scope Misrepresentation; COSMOS cert scope; CLOSED; 8 consumers notified); AQN-GWL-2026-006 (Level 3 — Misleading Omission; REACH SVHC in recycled plastic product; ACTIVE; 12 consumers notified); AQN-GWL-2026-007 (Level 1 — Irrelevant Claim; hormone-free where already prohibited; CLOSED); AQN-GWL-2026-008 (Fair Trade badge suspended; consumer report; UNDER REVIEW). Full Level 4 named entry (AQN-GWL-2026-004) reproduced in full. Section 5: Enforcement Statistics April 1-June 18 2026 (8 actions; 1 vendor termination; 1 regulatory referral; 43 consumers notified; CAD $2,340 + EUR €1,820 refunded; average closure time 11.3 BD; automated monitoring detected 50% of violations). Annual Transparency Report schedule. Section 6: Consumer rights if product affected (Level 4: full refund regardless of return window/condition; Level 3: full refund offered; Level 2: optional return; Level 1: no consumer impact); Consumer Rights by Jurisdiction table (10 jurisdictions: USA; EU; UK; Canada; Australia; Brazil; South Africa; India; UAE/Saudi/GCC; Nigeria with applicable law; rights; enforcement channel). Section 7: Consumer reporting process (6 provisions including anonymous reports and bad faith report consequences). Section 8: Log maintenance (5BD update; permanent archive; correction policy with struck-through notation; overturned entries retained); legal basis for public disclosure (EU DSA; UK OSA; EU GPSR; US First Amendment; Australian CCA; Canadian Competition Act); defamation safeguards; GDPR/privacy considerations for named entries. Contact directory (10 entries). Appendix A: version history. | Legal + Sustainability Officer + CCRO (Ronke Olatoye) / Ubon Isang (CEO) |
AqNova Marketplace | Arivon Holding Corporation | EIN: 41-3210066 | Huntington Park; California; USA
Greenwashing Enforcement Log (Public) | CLEAN Framework | Version 1.0 | Log Open: April 1, 2026
LIVE DOCUMENT — Updated within 5 business days of each enforcement action | verify@aqnovamarketplace.co
Referenced in: Sustainability & Verification Policy §7 · Seller Center · Vendor Agreement · Consumer Terms of Use · Cookie Policy