The Everlution Blog is devoted to discussing issues related to the ever increasing ecological footprint of human beings. If we have the determination, we can reduce that footprint, even with more population and more affluence. We have the technology to overcome human-induced climate change - the biggest issue we have ever faced. But we have to get going as our species is irreversibly altering the climate that has been stable for the last 800,000 years.
This is part two of a three-part series that discusses what greenwashing is, the rise of greenwashing claims, tips to avoid it and greenwashing put in the context of the new climate and sustainability-related financial disclosure rules.
Part 2: Tips to avoid greenwashing
In part one of this series, we discussed what greenwashing is and the rise of greenwashing claims. Greenwashing manifests itself in several ways – some more obvious than others.
Tactics include:
Claiming to be on track to reduce a company’s polluting emissions to net zero when no credible plan is actually in place.
Being purposely vague or non-specific about a company’s operations or materials used.
Applying intentionally misleading labels such as “green” or “eco-friendly,” which do not have standard definitions and can be easily misinterpreted.
Implying that a minor improvement has a major impact or promoting a product that meets the minimum regulatory requirements as if it is significantly better than the standard.
Emphasizing a single environmental attribute while ignoring other impacts.
Claiming to avoid illegal or non-standard practices that are irrelevant to a product.
Communicating the sustainability attributes of a product in isolation of brand activities (and vice versa) – e.g. a garment made from recycled materials that is produced in a high-emitting factory that pollutes the air and nearby waterways.
Tips to avoid greenwashing are:
Principle 1: Make accurate and truthful claims
All your claims should be true and accurate. Even claims that are factually correct can sometimes still mislead consumers. You should consider the overall impression created, including through use of visual elements. Only make claims that represent a genuine environmental impact and do not exaggerate the benefits or level of scientific acceptance of a claim.
Principle 2: Have evidence to back up your claims
It is good practice to ensure you have clear evidence to back up all your claims. Evidence that is independent and scientific is the most credible. Making the research, evidence, or data that you are relying on easily accessible to consumers helps consumers to understand and trust your claims. If you are making a representation about a future matter (e.g. something that you promise, forecast or predict will happen in the future), you must have, and be able to show that you have, reasonable grounds for making that representation. Otherwise, the representation will be taken to be misleading under the ACL.
Principle 3: Do not hide or omit important information
Consumers cannot make informed decisions if they are not provided with relevant information that gives the full picture, or if important information is placed where they are unlikely to notice or find it. Consider all the relevant information about your environmental impact and be transparent about it.
Principle 4: Explain any conditions or qualifications on your claims
Theoretical environmental benefits, which are not clearly explained, are likely to mislead consumers. Ask yourself if there are any conditions that need to be met or steps that need to be taken for your claim to be true. If claims are only true in certain circumstances, you should explain this to consumers clearly and prominently.
Principle 5: Avoid broad and unqualified claims
Broad claims can be interpreted widely and more easily mislead consumers than clear, specific claims that are substantiated. Ensure that you clearly qualify your claims, with prominent disclaimers, if there are any limitations to them.
Principle 6: Use clear and easy-to-understand language
Most consumers do not have specialist scientific or industry knowledge. It is good practice to use clear and easy-to-understand language and to avoid technical terms.
Principle 7: Visual elements should not give the wrong impression
Visual elements (for example green-coloured packaging, or logos representing a recycling process) on packaging and/or in advertising material can significantly influence a consumer’s impression of the environmental impact of a product or service. Avoid visual elements that would give the wrong impression about the environmental benefits of your product or service. You need to consider the overall impression that is created, taking into account not just the words used (or information that is left out), but also visual elements, colours and logos.
Principle 8: Be direct and open about your sustainability transition
You should be cautious about making aspirational claims about your future environmental objectives unless you have developed clear and actionable plans detailing how you will achieve those objectives. If you can transition to more sustainable business operations and want to tell consumers about it, be direct and open. Transitioning to a more sustainable business model takes time and is often not linear. For example, if you can’t reduce your greenhouse gas emissions in the short term, but are instead offsetting your impact on the environment, make this clear to consumers.
In Part 3 of this series, we discuss Greenwashing and the new financial disclosure rules.
References
Australian Competition and Consumer Commission. (2024). Environmental and Sustainability Claims. https://www.accc.gov.au/business/advertising-and-promotions/environmental-and-sustainability-claims
United Nations Climate Action. (2024). Greenwashing - the deceptive tactics behind environmental claims. https://www.un.org/en/climatechange/science/climate-issues/greenwashing