Greenwashing Assessment Framework

Impact

• Selective disclosure

  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, 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 (ASA, 2023a). A Dutch commission (called Reclame Code Commissie) found that the sticker on Chiquita bananas that claimed "CO2 Neutral" was misleading (Sabin Centre for Climate Change Law, 2024a). 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.

  1.1 Does the organization fail to disclose relevant information regarding the environmental claim being made, such as lifecycle or cumulative impacts?

  If yes...+

  IT'S GREENWASHING

  For assessing this indicator, it is important to understand whether a) the exact scope of action and b) the limitations or system boundaries are transparently communicated. Even if not all stages of life cycle or not all scopes/cumulative impacts can be assessed for the claim, if boundaries are clearly communicated (what is and what is not assessed) and there is a clear pathway of improving the coverage of scope, that is not a greenwash. Likewise, the claimed product/service should not contribute to any significant negative impacts on the environment nor should result in an undue transfer of such impacts (unless the total net environmental benefit has been significantly improved). Life Cycle Analysis (LCA) is the most often used tool to assess different environmental aspects, although this approach comes with limitations. When assessing a claim related to environmental impacts, the product/service’s impact over its whole life cycle (on and off-site) is relevant. For the organization's impacts, the GRI Standards could provide an extensive list of specific measures. For products, all production steps including (where applicable) extraction through production, use, and postuse need to be included. An LCA should follow internationally accepted standards (e.g. ISO14000 series (ISO 2006)). Claims lead to greenwashing where they reflect only part of the life cycle/impacts and do not make clear which part they refer to thereby creating a misleading impression about the overall impact on the environment.

  1.2 When making a comparison, does the claim provide insufficient information to assess the difference between the claim and alternatives?

  If yes...+

  IT'S GREENWASHING

  Absolute claims need to be supported by a high level of substantiation. Comparative claims such as “greener” “friendlier” "more sustainable" can be justified if the advertised product/organization/service provides environmental benefit over that of the organizations’ previous products/services or competitors’ products/services, and the basis of the comparison is clear. Similarly, if the advertised "better/greener" products/services only constitute a minority of the same product/service range within the organization creating the impression that it is the dominant type of product/service, this has to be transparently communicated, otherwise it falls under this category of greenwashing.

  1.3 Is a claim of environmental neutrality based on offsetting rather than reduction of direct environmental harm?

  If yes...+

  IT'S GREENWASHING

  Claiming biodiversity or carbon neutrality or a reduction of environmental harm based predominantly on offsetting can mislead people to believe that the claimant is doing more to mitigate environmental harm than they are. For many, overuse of offsetting risks justifying the continuation of business-as-usual practices that damage the environment. Decades of experience with offsets have proven that they are unlikely to provide real long-term gains to balance the certain, often irreversible, destruction resulting from certain business activities. Terms such as “climate neutral” or “climate positive” that rely on offsetting will be banned from the EU by 2026 as part of a new regulations on misleading environmental claims. IUCN, a respected global authority on the state of nature and what is needed to safeguard it, concluded that “…evidence is lacking as to the extent to which no net loss (NNL) / net gains (NG) and offset policies are achieving their goals or contributing to better biodiversity outcomes in the jurisdictions where they exist.” (IUCN, 2014) (NewClimate Institute, 2020). At the same time, well-meaning investments by organizations in environmental protection projects are very much needed and they can be communicated. To this end, NewClimate’s Climate Responsibility approach (NewClimate Institute, 2020) calls for financially supporting others’ climate action, and disclosing that support within company reports, while not using them to “net-out’’ own impacts.

• Empty claims

  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” (ASA, 2023b). Courts ruled similarly regarding Austrian Airlines AG’s claims on using 100% sustainable aviation fuel (ESG Today, 2023), 4AIR LLC’s ad on sustainable aviation (ASA 2023c), and the claim “Connecting the World. Protecting its future” by Deutsche Lufthansa AG (ASA, 2023d). The ASA ruled similarly regarding Austrian Airlines AG’s claims 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.

  2.1 Does the claim over-state positive improvements to the environment?

  If yes...+

  IT'S GREENWASHING

  Organizations can exaggerate the impact of their green practices by overstating their goals or commitments that a) have not been fulfilled; b) based on available information on current trends are unlikely to be achieved; or c) do not lead to any follow-up action with measurable and significant impact. Setting dates far into the future (e.g. decades) without regularly updated interim goals also falls under this category of greenwashing. Several authors associate greenwashing to a decoupling behavior (Siano et al. 2017) which this indicator intends to capture.

  2.2 Is the marketing budget disproportionately large compared to the budget allocated for the claim, or when compared to the marketing budget for other products or initiatives that are a higher proportion of the organization's activity?

  If yes...+

  IT'S GREENWASHING

  In 2020, the fossil fuel industry spent $10 million on Facebook ads selling “innovative” climate solutions and visions of a “lower-carbon future” (InfluenceMap, 2021). Although challenging to obtain, information about marketing budget may be crucial for assessing potential greenwash. One source could be the annual data available for the biggest companies' ad budgets (Statista, 2024). This indicator also captures those cases, where the marketing budget behind the claim/campaign is much larger when compared to the marketing of other products/initiatives with a higher proportion of the overall business activity (e.g. an energy company is disproportionately spending on communicating 'green' initiatives that make up a small fraction of its business). The most famous example of this form of greenwashing is ExxonMobil's marketing of biofuels made from algae, where the marketing budget was reportedly $100 million, the actual investment was $350 million, and the project itself was cancelled after it became clear that it would never achieve scale (Westervelt, 2023).

• Irrelevant

  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 (CMA, 2023). 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.

  3.1 Is the claim presented as voluntary when it is required by law or policy?

  If yes...+

  IT'S GREENWASHING

  Claiming that e.g. a product is free of certain substances if such substances are already prohibited by legislation/standard practice of similar organizations is greenwashing as it suggests that the organization is taking unusual environmental steps compared to others, when the same activity is required.

  3.2 Is an unrelated issue included in a claim about a particular environmental benefit?

  If yes...+

  IT'S GREENWASHING

  Not all environmental benefits are related. Positive organizational performance on one issue, such as emissions reduction, cannot "stand in" for activity on another issue, such as supporting biodiversity gains. Similarly, acknowledgement of environmental performance in one area, through receipt of awards or certification, cannot absolve an organization for responsibilities elsewhere.

• Falsehoods

  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 (ASA, 2022a); THE PACK PET Limited comparison of life cycle analysis in the UK (ASA, 2022b); and the Pathways Alliance’s net zero claims in Canada (Sabin Center for Climate Change Law, 2024b).

  4.1 Is the claim based on solutions or justifications that are not supported by scientific consensus?

  If yes...+

  IT'S GREENWASHING

  Claims may fall on a continuum of verifiable support to having little or no proof. To avoid false advertising claims, organizations need to be aware of and comply with relevant statutes and regulations that govern competition and advertising in their jurisdiction and industry. Falsity does not require illegality. This greenwash category is commonly used by organizations to suggest that their preferred solution is also an environmentally responsible one. For example, the fossil fuel industry recently began buying ads that portray natural gas as a green fuel source, when methane is a powerful greenhouse gas, or arguments that decarbonization would make energy unaffordable (Grist, 2021). If there is significant disagreement or doubt over the environmental impacts of certain practices/products/services, the organization should refrain from marketing the message altogether (European Commission, 2021). Whatever the reason for advertising a certain policy/activity/product, a case by case analysis is required to assess whether scientific consensus exists to support the claim.

  4.2 Does the claim contain statements that are not based on robust, independent, verifiable and generally recognized evidence?

  If yes...+

  IT'S GREENWASHING

  Evidence that verify claims should be easily accessible by the public. The documentation for claims needs to be up to date for as long as the claims remain in use in marketing.

  4.3. Is the claim based on implementation methodologies that are not clear or transparent, do not have robust metrics or are based on aggregated broader sector data that benefit the organization?

  If yes...+

  IT'S GREENWASHING

  Inadequate quantification is a common category of greenwashing. For example, natural capital accounting is a controversial methodology that attempts to put a price on nature and ecosystem. The approach has significant conceptual weaknesses and produces figures irrelevant for demonstrating the actual state of or change within the physical environment (e.g. emission cuts). Likewise, communicating on the wrong metrics, e.g., outcome instead of impact, intensity instead of absolute emissions, or using flattering aggregate figures could also fall into this category. For example, salmon farmed in open ocean pens have significant documented negative environmental impacts, but industry actors may use statistics from research on "aquaculture" to make environmental claims about the industry because other types of aquaculture, such as farming shellfish and seaweed, have documented positive environmental effects.

• Just not credible

  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 (ASA, 2023e) 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.

  5.1 Does the claim try to make the public feel positive about a product, service, or policy that is demonstrably dangerous, harmful, or unsafe?

  If yes...+

  IT'S GREENWASHING

  This indicator is intended to capture the green marketing of products/services/policies that are presumed to be dangerous or unsafe such tobacco or herbicides. Dangerous could mean containing substances that are toxic, hazardous to the environment, carcinogenic, mutagenic or toxic for reproduction (CMR), causing endocrine disruption to human health or the environment, persistent, bio-accumulative and toxic (PBT) without explicitly mentioning this fact when publishing the green claim. If expert studies give rise to significant disagreement or doubt over environmental impacts of certain practices/products/services, the organization should refrain from marketing the message altogether (European Commission, 2021). Highly controversial solutions involve the choice of ecologically counter productive practices that do not maintain or enhance the ecological quality. Having a stake in/supporting fossil fuels (including gas, oils sands, and hydraulic fracking), nuclear energy, agro-fuels from primary crops, utilization of bioenergy as transitional technology, intensive industrial agriculture, sustainable aviation fuels, bottom trawling, etc. are just few examples of such controversial practices. Further references to determine when proposed solutions/practices/products are considered questionable by science: IEA's Net Zero by 2050 report (IEA, 2021); Roe et al (2019); EAT-Lancet Commission on Food, Planet, Health (EAT, 2019).

  5.2 Is the claim disproportionately small or concerned with minor issues compared with the scale of the environmental impacts associated with the organization/practice?

  If yes...+

  IT'S GREENWASHING

  This indicator refers to positive environmental activities, products, or achievements that are very modest compared to the scale of the negative environmental harm associated with an industry or organizational practice. For example, in June 2023 the UK Advertising Standards Authority found that ads by Shell Ltd were likely to mislead because the ads gave the overall impression (ASA, 2023e) that a significant proportion of their business comprised of lower-carbon energy products without providing information on the proportion of their overall business model that comprised lower-carbon energy products.