Claim is poorly defined / broad so its real meaning is misunderstood
Examples
A recent example is the claim “Good for the planet” by plant-
based beverage and yogurt producer Alpro (UK) Ltd that the ASA
ruled as misleading in 2021 (ASA, 2021).
10.1 Has the claim failed to specify whether it refers to the product/packaging/service or just a portion?
If yes...
IT'S GREENWASHING
Claims can refer to a part/feature of a product/organization (or simply to the packaging) instead of the whole
product/organization creating confusion among consumers about the claim. A typical example maybe a plastic package
containing a new product which is labelled “recyclable” without further elaboration. The context of the claim does not
make clear if it refers to the plastic package or the product, therefore the claim is deceptive if any part of either the
package or the product, other than minor, incidental components, cannot be recycled.
10.2 Do the words of the claim have unclear or ambiguous meanings that are not defined?
If yes...
IT'S GREENWASHING
Words such as "sustainably sourced”, “eco-friendly”, “green”, “sustainable”, “non-toxic”, “biodegradable”, "natural", etc are
ambiguous terms. The absence of clear definitions for many green marketing terms has made it difficult for consumers to
weigh how credible these claims are. Statements such as ‘good for you, good for the planet, good for the future’ also
raise as many questions as they answer. Is it good for the planet because of the packaging, because of how the item is
produced, because it is healthy for you and the soil or simply because it's less harmful than similar products? Such
claims require substantiation, covering the whole lifecycle of the product. Similarly, one cannot just say that plant-based
burgers or pet food are better for the planet than a traditional meat burger/meat-based pet food. What ingredients contain
the plant-based product, how has it been produced, with what inputs and where was it shipped from? Unless clearly
defined and adequately substantiated with easily accessible, independent, verifiable scientific information, such claims
remain greenwash.
10.3 When making a net zero/climate-related claim, has the organization failed to follow relevant internationally endorsed guidelines?
If yes...
IT'S GREENWASHING
There is a wide range of terms and claims used by companies in addition to “net zero”, such as "carbon negative" or
"climate positive"; or that they seek to achieve "net negative" emissions or "deep decarbonisation"; or that they plan to
become "emissions-free" or achieve "zero emissions"; or that they are committed to a "1.5 degrees C pathway"; or invest
in low-carbon technologies”. "Most “net zero” targets involve vaguely-written plans with loopholes that allow emissions to
continue rising - often for decades after commitments have been taken. The Science Based Targets Initiative (Science
Based Targets, 2021) requires that "companies set targets based on emission reductions through direct action within
their own boundaries or their value chains" and "offsets are only considered to be an option for companies wanting to
contribute to finance additional emission reductions beyond their science-based target/net-zero” (Ibid). Established
international best practice guidelines in this area require that organizations/ countries: a) measure, track and regularly
publish their emissions according to the latest IPCC or GHG Protocol guidance (e.g. scope 1 and 2 emissions and scope 3 emissions to the furthest extent possible); b) have a clear strategy, implementation planning process and interim targets to reach any future single point targets AND c) develop and publish a long-term strategy with a decarbonisation pathway that prioritizes reducing own emissions.
Misleading imagery
Using visuals and symbols that induce a false perception of the organization's
greenness
Examples
In 2022 the ASA ruled that ads by Innocent Ltd which were
misleading because they implied (through imagery and lyrics)
that purchasing their products would have a positive
environmental impact when that was not the case (ASA, 2022c).
11.1 Does the claim use images of the environment that imply that the product or organization has a positive environmental impact that it does not have?
If yes...
IT'S GREENWASHING
The wording and overall presentation (i.e. layout, choice of colours, images, pictures, sounds, symbols or labels) has to
be truthful about the environmental benefit. If green imagery or colours are used, or environmentally friendly footage to
promote products or services, this should be treated as separate green claim which should be documented and
substantiated. This is a requirement under the Danish Marketing Practices Act and the EU Green Claims
Directive. A recent case by the UK's Advertising Standards Authority (Innocent Ltd t/a Innocent) (ASA, 2022c) showed that ads are considered misleading when they implied (through imagery and lyrics) that purchasing products was a choice which would have a positive environmental impact when that was not the case.
11.2 Does the claim systematically use images of the environment that are unrelated or a very minor part of their core operations?
If yes...
IT'S GREENWASHING
While organizations are free to use environmental imagery, the practice can be misleading if it implies that
environmentally responsible products or behaviour are a larger portion of their activities than they are or redirects
attention away from core business activities that are environmentally damaging. Supran and Hickey (2022) identify disproportionate use of environmental imagery in their analysis of social media communication by fossil fuel, aviation, and car manufacturing companies, with nearly half of posts featuring themes of "green innovation" detached from the companies' core offerings.
Jargon
Claim uses jargon / information that consumers cannot understand / verify
Examples
An example is "Developed with advanced Shiseido technology
and ingredients including Super Bio Hyaluronic Acid N for intense
moisture and Hydroxyproline to promote collagen production" —
the high concentration of chemical names in this text seeks to
provoke in the consumer the perception of a sophisticated
product, elaborated with the latest scientific technology, which will
be beneficial for her skin (Arroyo, 2013).
12.1 Does the claim use technical language/complex scientific jargon that makes it difficult for people to understand?
If yes...
IT'S GREENWASHING
Green claims containing words that only a specialist can understand is a commonly used variety of greenwashing. Often
riddled with industry acronyms, jargon is difficult for outsiders to understand. For instance, the Federal Trade
Commission (FTC, 2012, p. 62122) instructs to “use clear and prominent qualifying language to convey that a general environmental claim refers only to a specific and limited environmental benefit(s)”. This indicator relates to products and services as well as policies and public speeches.
Explore other ways organizations might be greenwashing
