Greenwashing Tool

Communication

• Vagueness

  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.

  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.

  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 upcoming EU Green Claims Directive. A recent case by the UK's Advertising Standards Authority (Innocent Ltd t/a Innocent) 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/informatio n 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.