Claim does not
reflect consistent
organisational
practice
Examples
A well-known case that illustrates the importance of this indicator
is IKEA and the sale of what it claimed to be FSC-certified timber
products, which were actually harvested illegally from Ukraine’s
old growth forests (see Earthsight’s 2020 investigations).
VI.1 Are the products, procurement practices, vision, public statements or other firm- wide practices and policies in conflict with the claim?
If yes...
IT'S GREENWASHING
This indicator can be assessed by searching if a contradicting product/policy/practice/statement by a representative
exists within the same organisation that makes a claim. For example, an organisation may publicly claim to be pursuing
environmental responsibility while continuing to invest in fossil fuel expansion through an investment portfolio
VI.2 Has the organisation using a voluntary certification scheme failed to create a due diligence policy to ensure that the product claim is genuine?
If yes...
IT'S GREENWASHING
A growing literature provides mixed evidence regarding the potential for certification to reduce environmental and social
impacts (Lambin et al., 2018). Many certification schemes are unable to protect ecosystems' and people’s rights, and
thus additional due diligence is required to provide an assurance of responsibly sourced produce. An effective due
diligence screening program allows an organisation to make an informed decision about whether it is safe to proceed
with the certification. Also, many certification and standards systems have a chain of custody model or traceability
approach, which is critical for downstream actors to understand who they are sourcing from. However, a Chain of
Custody standard might only prescribe handling processes, and not include social abuses or environmental issues that
could occur across the supply chain (ISEAL Alliance, 2020). This indicator ensures that when retailers or producers
communicate about their (own brand) products being certified they do not merely rely on voluntary certification schemes
but ensure that they have a regularly updated effective due diligence policy in place.
Dubious certifications & labels
Claim has
certifications that
are prone to
greenwash
Examples
One example is the issue of certifying what could be considered
“business as usual.” There has been evidence from NGOs (e.g.,
SeaChoice et. al., 2018) that shows that the Aquaculture
Stewardship Council (ASC) has weakened its standards enough
to be considered largely certifying 'business as usual'.
Furthermore, farms without indigenous consent have been
certified along with farms that had high sea lice levels dangerous
to wild salmon (thus failing several ASC standards’ key
requirements). Organisations, like the Changing Markets
Foundation (2022) and Greenpeace (2021), have been critically
assessing certification schemes that were not achieving the
claims that consumers were seemingly led to believe.
VII.1 Is the certification or label not verified by independent accredited body?
If yes...
IT'S GREENWASHING
When an organisation chooses to use a labelling scheme, symbol or certificate for marketing purposes, these should be
verified by an independent accredited body or a designated community stakeholder. Certain exceptions may exist to the
general requirement of "independent accredited body" such as when an add-on certification exist which relies on the
adherence to a well-established certification (e.g. the case of Demeter, which certifies biodynamic products of its own
members - this certification is conditioned by the adherence to biodynamic standards and organic certification). Another
exception may be participatory certification which is not to be considered a greenwash practise as long as the process is
accountable and transparent. *Note that all other greenwashing themes apply to the communication of
certifications/labels, not just this theme.
VII.2 Are the benefits of the certification not clearly communicated or easily accessible?
If yes...
IT'S GREENWASHING
The criteria of certification schemes need to demonstrate clear environmental benefits compared with competing
products/organisations, should be easily publicly accessible and labels cannot be capable of being confused with other
labels, including, for example, labels of publicly run labelling schemes or schemes of competitors.’ (European
Commission, 2016). "All certification schemes shall have a clearly defined scope and also indicate what is not included –
to avoid “scope creep”" (EDPB, 2021). An important element of transparency and increased accountability and credibility
of a certification scheme is the publication of key documents (e.g. standards, inspection guidelines, audit reports) and
information related to certification bodies and complaints on the organisation's website. These allow stakeholders to
evaluate the performance of certificate holders and supply chain actors against the certification scheme’s standards, and
to assess how good job the auditors and certification bodies have done. If information is not readily available on the
website, it should be available by requesting the standard owner.
VII.3 Can the standard owner or certification body be challenged through adequate and accessible complaint and objection procedures?
If yes...
IT'S GREENWASHING
Most certification schemes have a dispute or grievance mechanism that enables complaints to be made against certified
companies and operations, the conformity assessment bodies (CABs) and the scheme itself. A growing literature
provides somewhat mixed evidence regarding the potential for certification to reduce environmental and social impacts
(Lambin et al., 2018). Many certification schemes are unable to protect ecosystems' and people’s rights, and thus
additional due diligence is required to provide an assurance of responsibly sourced produce. An effective due diligence
screening program allows an organisation to make an informed decision about whether it is safe to proceed with the
certification. Also, many certification and standards systems have a chain of custody model or traceability approach,
which is critical for downstream actors to understand who they are sourcing from. However, a Chain of Custody standard
might only prescribe handling processes, and not include social abuses or environmental issues that could occur across
the supply chain (ISEAL Alliance, 2020). However, often these mechanisms and the cases heard under them are not
made public. They may not have clear processes or be easy to use, and complaints may not be addressed in a timely
and comprehensive manner. They may also not provide for effective compensation to be paid to those who have been
negatively affected. Certifications may also lack a third-party complaint procedure that ensures the process is fair and
independent. CABs should not be able to act as both certifier and complainant. Lacking these accountability mechanisms
mean the scheme can easily greenwash harmful activities.
VII.4 Does the certification scheme, label, or initiative certify business as usual; products that violate its standards; illegal, or environmentally destructive activities?
If yes...
IT'S GREENWASHING
To address concerns of greenwashing, certification schemes need to shift away their focus from certifying as much
volume as possible to concentrating on rigorous enforcement of standards and developing a strong monitoring and
evaluation (M&E) program. When any of the three conditions listed in the indicator question is true, the scheme can be
accused of greenwashing.
Political spin
Claim boasts of green commitments, while the same organisation lobbies against environmental laws
Examples
One specific example is shown in the brought to light by Unearthed (2021)
investigations, which released information about how ExxonMobil
continued to fight efforts to tackle climate change in the United States,
despite publicly claiming to support the Paris climate agreement.
The aviation sector is one of the strongest opponents of climate policy in
Europe. The International Airline Group and the four European airlines with
the largest disclosed CO2 emissions in 2019–Air France, KLM,
Lufthansa,and Ryanair–regularly obstruct lobbying efforts on behalf of the
climate. Despite publicly claiming to support reaching net zero carbon,
they have actively opposed key domestic and EU aviation policies on
climate, including the full inclusion of aviation in the EU Emissions Trading
System, kerosene fuel taxes, and ticket taxes on flights (InfluenceMap,
2021).
A more recent example is a complaint from Greenpeace Canada against
the Pathways Alliance, which is a coalition of six of Canada’s largest oil
sands producers. Greenpeace alleges that Pathways’ claim that they are
actively reducing emissions and helping Canada achieve its climate
targets are false and misleading. The Alliance tries to create the
impression that it is a climate leader, despite its member activities such as
advertising and/or openly speaking out against climate action and
regulations in Canada.
VIII.1 Has the organisation making the claim or helping a corporate entity making a claim lobbied in contradiction of that claim?
If yes...
IT'S GREENWASHING
Although it can be difficult to obtain evidence on lobbying lobbying (in which case 'unknown' could be the answer), there
are instances when such activities become exposed. Useful references are the OpenSecrets in the USA; and the
Transparency Register in EU; and the website https://corporateeurope.org/en/climate. A further suggested reference for
this indicator is InfluenceMap, which provides independent data and analysis on how business and finance are affecting
the climate crisis.
VIII.2 Is the organisation affiliated with think tanks, trade associations or other groups that spread environmental science disinformation and/or block environmental action in contradiction to its claims?
If yes...
IT'S GREENWASHING
Critical studies of environmental sustainability initiatives point to the need to evaluate the influence of (industry or other)
groups on organizations making green claims. Social network analyses (e.g., Brulle 2019; Farrell 2015; Pattberg 2007)
can be used to determine the policy position, funding contributions, or political involvement of think tanks, trade
associations or other groups. Affiliation also refers to profiting from, investing in, or collaborating with other organisations.
For instance, according to Client Earth, Chevron (which makes claims about reducing carbon intensity and investing in
renewable and “low-carbon” energies) is a member of a number of trade associations and lobby groups which have
sought to block a transition away from fossil fuels (the American Petroleum Institute, the American Fuel and
Petrochemical Manufacturers and the American Legislative Exchange Council). Studies show how these associations
have been responsible over recent years for obstructive lobbying practices against urgently needed climate policies and
laws, and there are concerns that Chevron - like many other fossil fuel companies - continues to fight climate measures,
including behind closed doors.
Co-opted endorsement
Claims that
greenwash
organisation's
activities are
endorsed by
other
organisations
Examples
Examples include British Cycling’s endorsement of Shell’s Net-Zero claims
(Dubbins, 2022); Aarhus University, which was paid by a Danish meat
producer to create evidence that supports claims of reduced emissions in
pork production (The Copenhagen Post, 2021); and partnerships between
the World Wildlife Fund and organisations such as Shell, Monsanto, and
HSBC that benefited from the group's green image while continuing to
carry out harmful environmental practices as usual (The Guardian, 2014).
IX.1 Does the organisation help publicise, endorse, or support another organisation's claim that is greenwash?
If yes...
IT'S GREENWASHING
This indicator assesses an organisation B and requires that a) there is an organisation A which has a claim that falls into
a greenwash category according to any of the indicators of this framework and there is an organisation B that supports,
endorses or helps to promote that claim OR b) organisation B makes a green claim while at the same time supports
harmful activities/policies of organisation A. A recent example is Aarhus University, which was paid and used by the
biggest Danish meat producer (Danish Crown) to produce evidence that supports their claim of reduced emissions of
pork (The Copenhagen Post, 2021). A less recent example is WWF, which has been accused of forging links with global
corporations that are using its name to 'greenwash' environmentally damaging activities (The Guardian, 2014).
Corporations such as Coca-Cola, Shell, Monsanto, HSBC, Cargill, BP, Alcoa and Marine Harvest have benefited from
the group's green image only to carry on their businesses as usual.
