Do you want to talk to your customers about your brand's sustainability efforts accurately and authentically?
Are you willing to have open and honest conversations with your audience about how we can collectively mitigate the climate crisis?
Well, then, you've come to the right place.
In this guide, we give you ten practical tips on how to avoid greenwashing in your marketing communications.
We have scoured the CMA's Green Claims Code and relevant CAP and ASA environmental claims guidance to understand which practices and behaviours are and aren't acceptable.
The case studies we talk about in this guide are based on real examples of greenwashing. Read on to find out how you can prevent your business from falling into the same trap.
Should I be worried about greenwashing?
The short answer: Yes! Unless you’ve spent the last year living under a rock, you probably know about the flurry of greenwashing litigation that has gripped courts all over the world.
Businesses are increasingly being accused of making misleading and deceptive statements about their sustainability and environmental credentials. This has cost them financially and reputationally.
It’s easier than you think to inadvertently breach the rules against greenwashing. Regulatory authorities take a strict approach. Read this guide before releasing any more external comms on your brand's environmental credentials.
What is greenwashing? Why is it bad? And why is it everywhere?
Let’s face it: there is no business on earth that is 100% sustainable or environmentally friendly. We all leave an environmental footprint of some kind.
Fuelled in part by the rise in consumer demand for environmentally conscious and responsible products, many businesses now try to present themselves as having a positive impact on the environment. In many cases, their statements do not reflect the reality.
This practice, otherwise known as greenwashing, is damaging for two reasons.
First, it prevents consumers from being able to differentiate between businesses that are genuinely committed to operating in a less environmentally harmful way and those that are happy to rampage through our finite natural resources and fragile ecosystems like there’s no tomorrow.
It takes away a key USP from genuine climate-conscious companies and dampens consumers’ good intentions to shop more sustainably.
It also disincentivises businesses from improving their products, packaging, and operations; if they can get away with pretending to be more sustainable than they are, why should they spend money trying to achieve that in reality?
Greenwashing stunts investment in the kind of sustainable innovation that could help us create better economies and systems for our shared planet.
So how can you differentiate the way you communicate with your customers? Bring your customers along with you on your sustainability journey in a way that is truthful and authentic – warts and all. Stop pretending to have the miracle fix.
Keep reading to discover our useful tips on how to talk about your environmental impact without landing your business in hot water.
How to avoid greenwashing
Part A: How should you talk about your product’s characteristics and features?
Tip No. 1: Don’t make general, absolute, or unqualified claims about your product’s environmental impact
This is by far the number one pet peeve of regulatory authorities, like the CMA and ASA.
You must avoid making absolute, general, or vague statements to ensure you comply with the Green Claims Code principle that environmental claims must be “clear and unambiguous”.
What is an absolute and unqualified claim? It is when you assert that a product has a certain characteristic without reservation or limitations. You claim that it is “eco-friendly’, “sustainable”, or “green”, without providing any supporting information to explain the circumstances and conditions in which this feature applies or whether it has any exceptions.
The ASA has warned businesses to exercise caution to avoid making absolute or exaggerated claims. In a previous ruling, it found an electric scooter retailer to be in breach of the advertising rules for presenting its products as being environmentally friendly in a general way.
The company was misleading consumers because it could not prove that the scooter had no negative environmental impact at all.
The bar is high for general and absolute claims, and it is extremely difficult to prove that even the saintliest of products does not have any sort of negative environmental footprint.
Our advice is to avoid making these types of claims entirely; they don’t stand up to scrutiny and won’t empower your customers to understand the consequences of their buying choices.
Tip No. 2: Check how your product labeling could be interpreted
The way you present your product, including its colours and imagery, can unintentionally give a false impression that your product is environmentally friendly. You are responsible for ensuring this does not happen.
The Green Claims Code specifically refers to the imagery, logos, symbols, and colours used in a product’s packaging as relevant when considering whether a business has made “truthful and accurate” claims about the environmental benefits or impact of its products.
Combined with the use of vague, general, and absolute claims, such suggestive labeling can give consumers an inflated and exaggerated sense of the sustainability of your product.
Case study: "Eco-friendly" dog toys
Your company sells chewable dog toys made from rubber. Most competing products on the market are made from plastic.
Your product packaging is white and green and contains leaf and plant imagery. There is a large slogan across the front of the pack that reads: “Eco-Friendly Dog Toys: Made from Rubber”. You do not provide any further information or explanation.
Your packaging gives customers the impression that your rubber dog toys have a positive, or at least no negative, environmental impact. While it’s true that rubber has certain benefits compared to plastic, including durability and biodegradability, it also has serious adverse environmental effects.
Rubber releases harmful and polluting chemicals when it breaks down and has also been linked to deforestation. This is crucial information that should be brought to consumers’ attention and used to qualify your claim of eco-friendliness.
A better way to present this product would be: (1) talk about the advantages of rubber-made toys in reducing plastic waste; (2) favourably compare them to competitors’ plastic products but qualify this with information about the harms associated when rubber breaks down in the environment, and (3) avoid the use of the absolute and unexplained term “eco-friendly’ and all associated imagery.
You should beware that when making comparative claims you must ensure those claims are “fair and meaningful”. Comparisons should be based on “important and verifiable features”; it should be clear what the comparison relates to; and you must give customers all the information they need to verify the comparative claim.
Part B: How should you share information about your manufacturing processes and supply chains?
Tip No. 3: Consider the full life cycle of the product and its parts
The ASA instructs businesses to consider the entire lifecycle of a product when assessing environmental impacts and to be transparent about any negative aspects. Avoid narrowly focusing on a few positive features or processes, if your product has an overall harmful effect.
The Green Claims Code states that the environmental impact of a product's components is relevant to assessing the product's impact as a whole.
You should not disproportionately focus on a minor aspect of the product that has good environmental credentials while ignoring other more fundamental and negative features of the product.
If you do want to talk about a particular environmental benefit, you should clearly explain the limited scope of such claims and be willing to speak openly with your customers about other phases of your product’s lifecycle that continue to have a negative impact.
Tip No. 4: Include all material information for consumers to make an informed decision
The Green Claims Code gives consumers the right to all relevant information relating to the source of a product's materials, the manufacturing process, product distribution, and the use and disposal of the item. This is intended to help them make an informed decision on your product’s environmental impact.
Marketers must comply with the principle that claims should "not hide or omit important relevant information”.
The ASA also warns marketers not to omit significant information regarding negative impacts resulting from the manufacturing process.
You cannot simply remain silent or selectively choose what information you share with your customers. You must give them a balanced and complete picture of the environmental impact of your product across its entire lifespan.
When deciding whether to disclose information, ask yourself: (1) would knowing this affect a customer’s decision to buy the product? and; (2) would the customer feel deceived if they knew about this after buying the product?
Case study: electric vehicles
You are an electric vehicle manufacturer that claims your products are the “sustainable” and “environmentally friendly” option. While this may be true in the context of driving emissions, this claim is too general and absolute and does not take into account the full lifecycle or manufacturing process of an electric vehicle.
Your claim ignores the fact that lithium-ion batteries used in electric vehicles are highly damaging to the environment; lithium mining destroys wildlife habitats and negatively affects biodiversity. Electric vehicle battery disposal also poses hazards to the environment.
A better way to present this product would be to specifically highlight the environmental benefits of reduced emissions from driving an electric vehicle compared to a petrol or diesel car while qualifying the statement with information on the negative environmental impacts that occur throughout the product’s lifecycle.
Part C: How should you talk about your product's disposal?
Tip No. 5: Provide sufficient information for consumers to understand claims and don’t assume a high level of pre-existing knowledge
When it comes to making green product disposal claims, you must clearly explain what the terms you use mean in the context of your product’s features and materials.
If only part of your product is recyclable, don’t attach any logos suggesting it is 100% recyclable. Even using the term “recyclable” alone without further explanation may be deemed misleading.
You should provide clear information on any constraints, processes, or timeframes involved in your product’s disposal. If you claim that your product is compostable, but a specific process is required to achieve natural composting, this should be made clear.
If your product is biodegradable but it takes months or years for the components to break down or they release toxins during this process you should provide this information to consumers alongside any claims regarding product disposal.
You must clearly state if customers need to take additional steps to recycle your product or its packaging beyond what they would normally expect to do (e.g., it cannot be recycled at home and must be taken to a special facility).
According to the ASA, claims that provide very limited information and use complex terms like “recyclable”, “compostable”, or “biodegradable” without providing sufficient information for consumers to understand what this means in practice are likely to be misleading.
Case study: plastic packaging
Your company sells deli products that come in a plastic pot with a plastic film cover. The packaging displays a large green symbol on the front with the slogan “100% recyclable pot”. The label on the back of the pot explains, in small print, that the plastic film lid is not recyclable at all, and the recyclable pot cannot be recycled at home and must be taken to a recycling centre.
The product disposal labeling on the front of the pot does not provide sufficient information to enable consumers to understand the extent of the product’s recyclability and any limitations that apply. Instead, it gives the misleading impression that the entire product is easily recyclable at home and that purchasing it will bring environmental benefits.
Part D: How should you communicate your net-zero transition plans?
Tip No. 6: Focus on short-term targets rather than ambitious future goals
You must take care when talking about your emissions reduction targets and what you are doing to achieve the Paris Agreement goals. You should not base your claims on aspirational future goals or set unrealistic targets (e.g., claiming to achieve net zero by 2030).
Such claims are inherently difficult to verify, and it is misleading to rely on them entirely to present your company as taking meaningful action to reduce its carbon footprint.
It is better to set out short-term, realistic goals and to demonstrate a clear strategy for reaching your target. Use the SMART framework to set and measure your goals.
Talk about the progress you have already made towards reaching your target, providing objective evidence to substantiate this. This is a more credible approach than setting out vague and over-ambitious net zero goals without a clear roadmap for achieving them.
Tip No. 7: Avoid using complex terms without explaining their meaning
An ASA survey found there was little consensus among consumers on the meaning of terms like “carbon neutral” and “net zero”. You should only use these terms if you can clearly explain what they mean in the specific context of your business and activities.
When talking about reducing your carbon emissions, you should be transparent about whether your strategy relies on carbon offsetting. This will ensure that you comply with the Green Claims Code principle to not omit or hide important relevant information.
Tip No. 8: Be open about any differences in scientific opinion
Carbon offsetting is a controversial topic, and you should avoid making carbon neutrality and net zero claims if you plan to rely on this method alone.
Make sure you acknowledge the different scientific opinions about the effectiveness of carbon offsetting and that you clearly explain that offsetting does not involve the actual reduction of carbon emissions resulting from your business activities.
Case study: “emissions-free” deliveries
A delivery company prints large signs on the side of its electric vans claiming that “this delivery is 100% emissions free". The van provides no further explanation and does not qualify this claim in any way.
The van used to courier packages does not emit any driving emissions, but this general claim fails to acknowledge the emissions produced by the international freight transportation of the goods to the UK, or the emissions produced in generating the electricity used to power the electric van.
The claim is therefore inaccurate because the process of delivering the goods inside the van from start to finish has produced carbon emissions.
There is no attempt to explain or qualify the claim and its absolute nature gives the false impression that the company's delivery method is entirely emissions-free and therefore beneficial for the environment.
Part E: General Tips
Tip No. 9: Back up your claims with evidence
This one is a no-brainer but it’s astonishing how many companies make environmental claims that they don’t have objective evidence for. The Green Claims Code and the ASA Guidance both make it clear that all sustainability claims must be fully substantiated.
Tip No. 10: Be socially responsible in the way you market or advertise your products
The ASA states that marketers must be socially responsible when creating advertising campaigns. You should not trivialise consumer behaviour that results in harmful pollution or encourage the ordinary waste disposal of recyclable goods.
You should also be careful not to condone consumer behaviour that disregards the environmental impact of their actions. You may recall that the ASA recently banned a television advert by Toyota that showed environmentally damaging methods of driving.
We hope this guide has helped you understand how easy it is to inadvertently fall into the greenwashing trap and has given you practical tips on how to communicate with your customers in a more ethical, accurate, and accessible way.
When it comes to working together to protect our shared environment, honesty really should be the best policy!
At Green Path to Global, we craft clear and engaging content for climate-conscious and socially-ethical brands. Contact us today to see how we can help you avoid the risks of greenwashing and communicate your sustainability efforts in an accurate, authentic, and ethical way.
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