Claim is based
on a
narrow set of
attributes
and distracts
consumers from
the
organisation'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.
I.1 Does the organisation 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 organisation'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,
I.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/organisation/service provides environmental benefit over that
of the organisations’ 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 organisation 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.
I.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.” At the same
time, well-meaning investments by organisations 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”. 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.
II.1 Does the claim over-state positive improvements to the environment?
If yes...
IT'S GREENWASHING
Organisations 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.
II.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 organisation'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 (Business Chief, 2020). 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. 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.
III.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 organisations is greenwashing as it suggests that the organisation is taking unusual environmental
steps compared to others, when the same activity is required.
III.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 organisational 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 organisation 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; 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.
IV.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,
organisations 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 organisations 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 organisation should
refrain from marketing the message altogether (European Commission, 2016). 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.
IV.2 Does the claim contain statements that are not based on robust, independent, verifiable and generally recognised 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.
IV.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 organisation?
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 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.
V.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 organisation should refrain from marketing the message altogether (European
Commission, 2016). 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).
V.2 Is the claim disproportionately small or concerned with minor issues compared with the scale of the environmental impacts associated with the organisation/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 organisational 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 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.
