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If an organisation is claiming to be more sustainable or ‘eco-friendly’ than they actually are, it’s called greenwashing. But when does clever marketing become greenwashing, and when does positive PR become an overreach – misleading the people we want to impress?

Even where there is no intent to mislead, it can feel like a fine line to tread. A wobbly tightrope to walk, to share the positive actions being taken to reduce environmental impacts, with the big picture complexity of a work-in-progress. What to say, when, and to whom? The Green Claims Code can help us navigate these questions.


Protecting reputational risk

The Green Claims Code offers a guide for the decisions we make in marketing, advertising and PR, so that organisations can stay the right side of consumer law. The guidance has been issued by the Competition & Markets Authority (CMA), designed to protect consumers from misleading information that may impact their decision to buy.

But this is not just a matter for consumer-facing organisations. Not just for big brands. Wherever your business sits in the supply chain, the claims we make about our environmental impacts should be accurate, unambiguous and evidenced. After all, organisational reputations are built on trust. When that trust is broken, the reputational damage can be long-lasting – and expensive.

Building an organisation’s reputation through effective PR has always included the presentation of ‘our best selves’. We highlight the skills, impacts, insights or actions that we’re most proud of; those that we think will resonate with the people we want to engage or influence. We look for the eye-catching snapshots, the punchy headlines, we ‘edit’.


A brief history of greenwashing

As a term, greenwashing goes back to the 1980s – coined by Jay Westerveld when referring to hotels which promoted the reuse of towels to ‘save the environment’. They were, in fact, simply saving costs.

But as a concept, it’s much older – probably first appearing in the ‘Keep America Beautiful’ campaign in the ‘50s. It wasn’t called greenwashing then, in fact it was somewhat provocatively referred to as ‘ecopornography’ by Jerry Mander – when describing advertising which attempted to project a false green corporate image.

In the post-millennial era, interest and awareness of it has skyrocketed since the pandemic – as you can see by Google Trends searches for ‘greenwashing’ from 2020.

The advent of greenhushing

When falling foul of greenwashing can lead to loss of reputation and, if consumer law is found to have been breached, significant financial penalties, it’s hardly surprising that the ‘say nothing’ approach may seem appealing.

But this, too, is problematic. Greenhushing, which refers to deliberately keeping quiet about an organisation’s sustainability goals or activities, avoids the scrutiny of stakeholders. It can be construed as obscuring the truth of an organisation’s responsibilities. Again, this can present ‘trust issues’ impacting organisation reputation.

So, which way to turn? This is where the Green Claims Code can help.


Following the Green Claims Code

Under the Green Claims Code, if you’re making a statement, creating a campaign, or saying something in the public sphere that might fall into the realms of a ‘green claim’ – it should abide by these 12 tenets:

  1. It’s accurate and clear for all to understand
  2. You have current and credible evidence to prove it
  3. Any conditions or caveats are stated and easily understood
  4. It doesn’t mislead customers or suppliers
  5. It doesn’t contain any partially correct, or incorrect, information
  6. It doesn’t exaggerate positive environmental impact
  7. It doesn’t exclude or hide information about environmental impact that people need to make informed choices
  8. If more information is required and doesn’t fit into the claim, it can be easily accessed elsewhere
  9. Any features or benefits which are standard or legally required aren’t claimed as environmental
  10. The claim tells the whole story of the product, or specific part of the product, being described
  11. General claims reflect the whole lifecycle of the product, justified by evidence, and durability or disposability information is clear
  12. Comparisons are fair, accurate, and clear for all to understand

In practice, that boils down to following these six principles when you make a green claim:

  1. You must be truthful, honest, and accurate.
  2. You must be transparent, straightforward, and unambiguous.
  3. If you make comparisons, they must be relevant and fair.
  4. You must not hide anything relevant to your claim.
  5. You must be able to prove your claim.
  6. You must address the full life of your product or service.

What the Green Claims Code means for your PR & Marketing

At its heart, the Green Claims Code is about truth and misinformation in sustainability. In everyday practice, it’s about our choice of language, paying the utmost attention to accuracy and specificity – saying the right things, in the proper way, and not exposing yourself to risk and accusation.

To avoid damage to your brand, and potential fines if you breach consumer law, here are a few suggestions from the Target team for embracing the Green Claims Code:

Conduct a Green Claims Audit
The Green Claims Code covers everything you say, wherever you say it. That means website content, press, marketing collateral, packaging, and video content too. So, first thing’s first, you need to go over your current materials with a fine-tooth comb and check any green claims against the key principles of the code.

Keep a tracker and mark any claims that need revising or removing – going back to historic content which is still live, like blog posts on your website. Obviously, there is little that can be done about historic press releases once they’re picked up, but you want to be able to prove that you’ve taken the necessary steps to make any live content compliant.

The code stipulates the words ‘green’, ‘sustainable’, and ‘eco-friendly’ as the areas of focus – so make this your starting point for finding any potential offenders.

Create internal guidelines
While most of the Green Claims Code is common-sense-thinking about honesty and integrity, there are some areas where your internal colleagues (or agency partners) may appreciate a little guidance. You can signpost to official guidelines, but better yet is to create a set of principles which are super-focussed on your business.

The stipulations about product life cycles and legally required benefits are going to be likely tripping points, so bring these to life with examples of how they might suit your product or service. Develop a core set of some common statements, evidenced messages, that everyone can use. The more easily applied to your business, the easier your colleagues will be able to follow them.

Carry out training
For media-facing leaders and marketing teams, it’s a good idea to put on a workshop which really delves into what the Green Claims Code means. These are the people most likely to be making the claims and therefore those which need to be the most careful.

Nominate a Green Claims Lead
Bake greenwashing into your sign-off and approvals process for all external content. Add a step into your fact-checking exercise to make sure that no risky green claims are being made, or nominate somebody specific who understands the rules – to give everything a once-over before publication. If you think about this as an added step in the process of looking after your customers, like the extra precautions you began to take once GDPR came into effect, you’ll be thinking along the right lines.

Getting this right isn’t just about avoiding reputational damage. It’s about contributing to the biggest environmental issues that we are all facing, changing the behaviours that cause damage, and encouraging the actions that will, ultimately, collectively, change the outcome.

We need to share the positive learnings from our organisations and acknowledge the challenges we still face.

It’s a communications challenge that the Target team is committed to addressing with our clients, and if it’s something you’re grappling with at the moment, we’d love to hear from you.

Discover more about the Green Claims Code here:

Green Claims Code