Claim is based
on a
narrow set of
attributes
and distracts
consumers from
the
organization's
greater
environmental
impact
- Examples
- A typical example of selective disclosure are claims of net zero or climate
neutrality that omit key details. For instance, last year, the UK’s
Advertising Standards Authority found an ad by Repsol SA to be
misleading regarding information about how and when they would achieve
net zero emissions. In addition, the advertised production of biofuels and
synthetic fuels for achieving net zero emissions was only a small fraction
of their business activities when compared to substantial, ongoing, and
expanding fossil fuel production. Another common example is the
reference to climate or CO2 neutrality. A Dutch commission (called
Reclame Code Commissie) found that the sticker on Chiquita bananas
that claimed "CO2 Neutral" was misleading, since it did not contain any
reference to information about its interpretation. This leaves the meaning
of the claim unclear to the average consumer who may therefore assume
that their purchase was not harmful to climate change or the environment.
Making claims/policies
that either
exaggerate
achievements, or
fail to live up to
them
- Examples
- A recent example from the aviation industry are the ads that featured the
claim “we are taking a louder, bolder approach to sustainable aviation” by
Etihad Airways. The UK’s ASA understood there were currently no
initiatives in operation within the aviation industry that would adequately
substantiate such an absolute green claim like “sustainable aviation”. The
ASA ruled similarly regarding Austrian Airlines AG’sclaims on using 100%
sustainable aviation fuel, 4AIR LLC’s ad on sustainable aviation, and the
claim “Connecting the World. Protecting its future” by Deutsche Lufthansa
AG. In general, these absolute claims within the aviation industry could not
be adequately substantiated and therefore are empty claims.
Proclaiming
accomplishments
that are irrelevant
or already
required by
law/competitors
- Examples
- Examples include an ongoing case by the UK’s Competition and Markets
Authority, which started investigating Worcester Bosch’s marketing
claimsabout its so-called ‘hydrogen-blend ready’ home boilers. The
investigation is looking into whether the company has been misleading
consumers with confusing green claims by stating that the boilers can run
on a blend of 20% hydrogen and natural gas–something that is required by
law anyway.
The claim cannot
be substantiated
by accessible
supporting
information
- Examples
- One highly publicized example from the US is ExxonMobil, which
publicly denied the realities of global warming despite studies by
its own scientists showing the negative impacts of burning fossil
fuels (Supran et al., 2023). Examples of inadequate quantification
have come up in litigation cases such as: Oatly UK Ltd t/a Oatly
comparison of emissions; THE PACK PET Limited comparison
of life cycle analysis in the UK; the Hunton’s use of dynamic
lifecycle analysis in Sweden; and the Pathways Alliance’s net
zero claims in Canada.
Claim touts
environmental
friendly attributes
of a
practice/policy/
product that is
environmentally
harmful or
focuses on minor
issues
- Examples
- For example, in June 2023 the UK’s Advertising Standards
Authority found that ads by Shell Ltd were likely to mislead
because they gave the overall impression that a significant
proportion of their business was comprised of lower-carbon
energy products without providing information on the proportion
of their overall business model that comprised lower-carbon
energy products.