CSSN Special Projects

Greenwashing Assessment Framework

How do you think an organization might be greenwashing?

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...+
    1.2 When making a comparison, does the claim provide insufficient information to assess the difference between the claim and alternatives?
    If yes...+
    1.3 Is a claim of environmental neutrality based on offsetting rather than reduction of direct environmental harm?
    If yes...+
  • 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...+
    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...+
  • 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...+
    3.2 Is an unrelated issue included in a claim about a particular environmental benefit?
    If yes...+
  • 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...+
    4.2 Does the claim contain statements that are not based on robust, independent, verifiable and generally recognized evidence?
    If yes...+
    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...+
  • 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...+
    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...+

Explore other ways organizations might be greenwashing