Greenwash guide


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Greenwash guide

  1. 1. ContentsThe two minute version10 signs of greenwashThe temptation of greenwashA short history of greenwashThe world wakes up to greenwashGreenwash: Annoying or dangerous?And the industry response is…Goodbye greenwashA virtuous or vicious cycleA greener futureLearn moreEnd notes12461418222636384041
  2. 2. And greenwash is growing. The AdvertisingStandards Authority in the UK is upholding more andmore complaints against advertising that can’t liveup to its green bluster. Around the world regulatorsare trying to keep up, and the USA’s Federal TradeCommission has brought forward to 2008 its planto review their environmental marketing guidelines.France has just announced new guidelines andthe UK is reviewing the advertising Green Claimsguidance. But is this enough?Why all the fuss?Greenwash isn’t simply annoying, it’s dangerous.In a market economy the consumer is king,and consumers have started sending strongenvironmental signals through their purchasing. Thisgrowing ‘green pound’ is a powerful force compellingthe economy to clean up its environmental act.But consumers often rely on advertising and othercorporate messaging to inform their purchasingchoices, and greenwash is undermining confidencein that advertising. That confidence is now at an alltime low, with only 10% of consumers trusting greeninformation from business and government1. Withoutconfidence in the claims, consumers are reluctant toexercise the power of their green purchasing, as theyno longer know who or what to believe. This putsthe whole market for the ‘green pound’ in dangerand might damage the virtuous circle of companiespromoting their green products, consumers choosingthem over non-green products thereby encouragingThe two minute versionGreenwash is with us, and unless we take action, it is likely to be with us tostay. Greenwash is an environmental claim which is unsubstantiated (a fib)or irrelevant (a distraction). Found in advertising, PR or on packaging, andmade about people, organisations and products. Greenwash is an old concept,wrapped in a very modern towards greater greenness. Greenwashis the spanner in the works that could sabotage thewhole environmental movement within business.This guide reveals the industries most activelygreenwashing, and those environmental claimsmost likely to be greenwash. Not enough is beingdone to prevent this accelerating negative feedbackloop. None of the UK’s biggest advertising agenciesclaim to have training or guidelines for their staff onwhat is a justified green claim. And none of the mainpublications in the UK who sell advertising spacehave their own standard.It’s not all bad newsMost greenwash is due to ignorance and/or sloppiness rather than malicious intent, andbusinesses and advertising agencies can take simplesteps to prevent greenwash slipping through. As aconsumer, you too can spot the worst greenwashsymptoms, and this guide lists the simple tests for‘greenwash’ versus ‘good claims’. Tear off and keepour simple Greenwash Guide postcard for whenyou’re shopping.At a time of impending economic challenges, it’smore vital than ever that green messages havecredibility. The next few years will demonstrate iftogether companies, agencies and consumers canspin the virtuous circle, or if runaway greenwash willbring the new green revolution crashing down.1
  3. 3. From the international codes and research for thisreport we have identified 10 signs of greenwash, be itin an advert or a speech by a government minister.
  4. 4. Cutoutandkeep1. Fluffy languageWords or terms with no clear meaning,e.g. ‘eco-friendly’2. Green products vdirty companySuch as efficient light bulbs made in a factorywhich pollutes rivers3.Suggestive picturesGreen images that indicate a (un-justified) greenimpact e.g. flowers blooming from exhaust pipes4.Irrelevant claimsEmphasising one tiny green attribute wheneverything else is un-green5.Best in class?Declaring you are slightly greener than the rest,even if the rest are pretty terrible6.Just not credible‘Eco friendly’ cigarettes anyone? ‘Greening’a dangerous product doesn’t make it safe7.GobbledygookJargon and information thatonly a scientist could check or understand8. Imaginary friendsA ‘label’ that looks like third party endorsement …except it’s made up 9. No proof It could be right, but where’s the evidence?10.Out-right lyingTotally fabricated claims or data
  5. 5. Actually there is a very simple answer to thisquestion. It’s that you, the consumer, have started tochange your buying patterns in a way that has caughtthe advertiser’s eye.Consider the example of ‘organic’ for a moment. TheCo-operative Bank discovered that organic food salesin this country have doubled since 2000 and are nowgrowing at an average of 25% per year2. By 2010the organic market will be worth at least £2billion3.Think back only a decade or so and imagine trying tobuy ‘organic’ in a high street supermarket. Organicthen was for real green enthusiasts; the Good Lifetypes. Today organics is a huge, and relatively young,market spilling out from food to new ‘marketingcategories’ such as beauty products.And new markets make marketers twitchywith excitement.New green poundOverall, so called ‘ethical’ spending in the UK hasjumped by 81 per cent since 20024; most of us have,in the last year, bought free-range eggs, or productswith recycled content (like loo roll) or drunk fair-tradecoffee. At a conservative estimate of £29.7bn5, themarket is still relatively minor, but big companies cansee the writing on the wall. Green has gone from thesmallest of niches to a very desirable market all setto grow. There’s money to be made and that’s thegreatest temptation of all.Of course it’s not only purchasing habits that areshifting, so are public expectations of companies’behaviour. An overwhelming majority of ussay companies should improve the social andenvironmental impacts of their products and servicesand 83% of us claim to think about a company’s greenreputation when we shop (a hard core 38% feel this isvery important) 6.So alongside the big juicy organic carrot of the‘green pound’ is the threatening stick of customers’growing expectations of action. These temptationshave led to a boom-town attitude towards green andethical advertising.Show me the moneyAccording to reports nearly £17 million was spenton advertising containing the words ‘CO2’, ‘carbon’,‘environmental’, ‘emissions’ or ‘recycle’ fromSeptember 2006 to August 2007 alone. A similarsearch for the same terms in 2003 uncovers only£448k7of advertising. And that new spend wasn’tcoming from traditionally ‘green’ companies. Thedeepest pockets are said to be Veolia Environment,Exxon Mobil, the UK government, BSkyB and Marks& Spencer.The numbers aren’t in for this year yet, but we canexpect to see that spend has doubled or more.Advertising is expensive, and it’s not an exact science- as Lord Lever the founder of Unilever purportedlyacknowledged, “half our advertising is wasted; I justdon’t know which half”. This growth in selling greenis a sign of things to come: you want to buy green,you expect companies to be green, and they haveeagerly started to tell you that they are… occasionallywithout good reason for doing so. Enter greenwash.5
  6. 6. A short historyof greenwashGreenwash is nothing new, but the currentscale of it is. Industries that have neverhad a problem are now getting in on theact. And the world is watching.
  7. 7. As we will see, the themes ‘unfounded’ and ‘irrelevant’ areequally important in judging greenwash, even if most of usare more concerned with the first crime: that of fibbing.Green wordsThe term greenwash only officially became part ofthe English language in 1999 with that entry into theOxford English Dictionary, but it’s been around a lotlonger than that. In fact the first recorded use of theterm was by David Bellamy in the periodical Sanityover twenty years ago. By Earth Day in 1990 theconcept was catching on. Most greenwash back thendidn’t include specific claims or marketing messages;instead it was more ham-fisted images of frolickingdolphins and lush rainforests set beside the companylogo, all to convey an impression of eco-friendliness.These early attempts to green a company’s imagenow seem laughable, especially when you thinkthat Bhopal, Exxon Valdez and other environmentaland social corporate disasters were still fresh in thememory. But even these early attempts at greeningcompany images didn’t stay fashionable and the1990s saw only occasional greenwash spikes. Thosewere the years of specialist green products andoutlets like the Body Shop. Although greenwashMotoring sectorThe full, and rather difficult toread, version of the Oxford EnglishDictionary defines greenwash as;“Disinformation disseminated byan organisation, etc., so as topresent an environmentallyresponsible public image; a publicimage of environmentalresponsibility promulgated by orfor an organisation, etc., butperceived as being unfounded orintentionally misleading.” 8Perhaps more simply put (withoutwords like ‘promulgated’),greenwash…misleadverts the public by stressingthe environmental credentials of aperson, company or product whenthese are unfounded or irrelevant.8
  8. 8. Utilities sectorEnergy sectormay still have been around, the audience affectedby it was small and the spending on communicationslow. Only with the recent green wave, when greenconsumption first dissolved its boundaries andentered the mainstream, has greenwash raised itshead again.
  9. 9. Since then concern about greenwashhas boomed. Press coverage andblog searches all show how much‘buzz’ around greenwash is currentlyout there:Media coverage of‘Greenwash’, based ona review of 30 nationalUK newspapersBlog buzz on‘greenwash’, basedon a Google blogreview10
  10. 10. Environmentalclaims complaintsformally investigatedby the ASA,2004 - 2007Greenwash boomsThis huge rise in interest about greenwash has onevery tangible measure. The Committee of AdvertisingPractice (CAP) Code, enforced by the AdvertisingStandards Authority, first created a clause forenvironmental claims in 1995, and since 1998 theUK government has published a non-binding ‘GreenClaims Code’, advising advertisers on how best tomake good claims. Read on for a short overview ofthe British government’s Green Claims Code andhow it compares to its international counterparts. TheASA sets out the rules for advertisers in talking abouttheir green credentials, product and science claims.If a member of the public believes an advert hascontravened those rules then the ASA can force thecompany to pull the advert.About 10% of the complaints are actually fromcompanies setting out to rubbish their competitors’green claims. The battle between the train and theplane reached heightened levels of animosity earlierthis year when easyJet complained to the ASAabout a Virgin Trains ad campaign, which claimedthat a train journey emits 75% less carbon dioxidethan a similar trip by air. Ironically, easyJet’s protestcame just weeks after it was criticised by the ASA forinaccurately portraying the green benefits of itsnew fleet.The wages of sinBeing criticised by the ASA can be hugely costly asthe company is unlikely to receive a refund for anyadvertising space or broadcasting slots it’s alreadypaid for. This alone should be a disincentive togreenwash, yet we find that year-on-year the ASAhave received more complaints on environmentalclaims, and upheld more of those complaints,thereby forcing the advertiser to alter or cancel thecampaign.The graph below shows only a steady increase inupheld formally investigated complaints since 2005,despite a sharp rise in overall formally-investigatedcomplaints since 2006. One thing not shown hereis how many people complained: a single advertcould have many individual complaints lodgedagainst it, and astonishing figures from the ASA’sAnnual Report 2007 reveal that total environmentalclaims complaints against all ads (whether formally-investigated or not) have risen five fold since 2006 –surely proof of consumers’ increasing concern aboutgreenwash.11
  11. 11. Adverts formallyinvestigated forenvironmental claimsby sector,2007 (top) and2006 (bottom).Source: ASA websiteAnalysis: FuterraWorst sinnersIt is perhaps no surprise to find in the charts belowthat utilities (energy and water companies etc) havestayed favourites for upheld complaints to the ASA.But since 2006 the numbers for car companies andholiday firms have climbed. The ‘non-commercial’sector includes the UK government (although itreceives an awful lot more complaints from climatechange deniers than are upheld), and also pressuregroups, whose adverts and leaflets are subject to thesame rules as companies.12
  12. 12. Formally investigatedupheld infringements.Source: ASA website.Analysis: FuterraGreenwash itself has its fashions.Based on the Broadcast and non-Broadcast Committee of AdvertisingPractice codes, the graph belowshows the most popular infringementsfor upheld environmental claimscomplaints from last year and 2005.Worst sinsThe chart above refers to specific clauses and parts of theBroadcast and non-Broadcast Committee of AdvertisingPractice Code. All figures are for formally investigatedadverts, and we find a clear but perhaps unsurprisingtrend that infringements have significantly increased inthe last two years, while incidents of vague, exaggeratedor otherwise dodgy comparisons have rocketed fourfold.Clearly, claiming to be ‘greener than thou’ has become afavourite tactic – but not one that will escape the notice ofthe ASA.The fact that ‘truthfulness’ and ‘substantiation’ are the mostfrequent infringements shows that, when adjudicationsare made, the ASA views greenwash not as a niche,sector-specific matter but as a threat to the foundation ofadvertising: consumers’ trust.Greenwash UKAll of the above provide a picture of greenwash inthe UK that is somewhat worrying. The phenomenonis becoming more widespread and the issues aregrowing more complex. This is not going unnoticedand the news and blog tables demonstrate thatexpressing concern about greenwash is almost aspopular as the problem itself. The question remainshowever, does any of this matter?13
  13. 13. The worldwakes upto greenwashAn interesting guide to International Codes
  14. 14. Attempts to regulate the increasingflow of greenwash around the worldactually predate the most recentflood of complaints by some years.Across the world different guidelinesand rules are in force to stem thetide. Most are up for review as youread this.
  15. 15. As far back as 1992 the United States EnvironmentalProtection Agency and Federal Trade Commissionjointly published a set of ‘Guidelines for EnvironmentalMarketing Claims’9. They weren’t easy to enforce andwere somewhat vague but they did signal that ‘green’issues couldn’t be a free-for-all for advertisers.Although they set the early rules, they missed classicgreenwash errors such as the use of environmentalvisuals and pictures (images of verdant naturalscenery with the product centre stage), that maymake you think ‘green’ without it ever being said, ormaking claims that while literally true are unlikely tohappen in practice (e.g. the biodegradable bin-bagthat is only truly biodegradable when separated fromthe rubbish it contains). In 2003 the UK Governmentrevamped their own ‘Green Claims Code’10. Thiscode did address previous omissions like those listedabove and made specific reference to the then newInternational Standard on Environmental Claims ISO14001. For the first time enlightened consumers hada benchmark against which to test green marketersclaims, and criteria on which to base complaints.Under the auspices of the Committee of AdvertisingPractice code, the UK Advertising StandardsAuthority can pro-actively investigate a potentiallyspurious claim. However, the majority of adverts areformally investigated following complaints from thepublic and other parties (such as commercial rivals).Just one complaint is required to trigger a preliminaryinvestigation, so the public has great responsibility tomake noise about dubious marketing practices andalert the ASA to unclear, unfounded or misleadingenvironmental claims.Global greenwashOther countries are either using the ISO standard orbringing in their own. The most recently publishedguidance in Australia, ‘Green Marketing and TradePractices Act’11, and France’s new ‘Charte’, show justhow far the need for tighter regulation has grown.The Australian guide, by tying its advice tightly toexisting legislation (The Trade Practices Act 1974),is much more assertive warning businesses thatsubstantiating green claims is not only good practice,it’s the law and attempts to mislead or deceiveconsumers carry serious penalties.The French have taken a slightly different approach.Building on the work of the ‘Bureau de Verificationde la Publicité’, which became a moral (but notlegal) arbiter on green claims in 1998, this year theylaunched the ‘Charte d’engagement et d’objectifspour une publicité eco-responsible’. Led by a juryof advertising professionals, the Charte enablesthem to impose fines and enforce the withdrawal ofenvironmentally misleading campaigns12.Finally the recent rash of green advertising emanatingfrom the motoring industry led the NorwegianConsumer Ombudsman’s office to issue a warning onenvironmental claims about vehicles13under the legalcover of the Marketing Control Act. Befuddled bymultiple claims to the title of ‘most environmentallyfriendly vehicle’ or ‘cleanest engine’ the Ombudsmanoutlined clear instructions about the quantificationand comparability of competing claims and gave allinvolved a set time period to sort their acts out…or else.Future developmentsDuring 2008 the USA are reviewing their code andthe UK is considering further guidance on theirs.It’s likely that the Australian, French and Norwegiancodes will all encourage other countries to considergreenwash rules. Of course, greenwash doesn’tmean the same wherever you are. One apocryphalstory has it that a climate campaign run by a largecompany across the UK, USA and China was accusedof greenwash in the first, hailed a brave in the secondand pulled because of government upset at beingimplicitly criticised in the last.The next twelve months should be interesting forthose planning worldwide green marketing campaigns.16
  16. 16. AUS – AustraliaFRA – FranceNOR – NorwayUSA – United States of AmericaUK – United Kingdom17
  17. 17. Greenwash:Annoying ordangerous?There does seem to be a lot of greenwashout there, and the temptation for more issignificant. But you could question…is itreally a problem?
  18. 18. A delicate balanceBut you’d actually be right to be worried. Greenwashis having an insidious, measureable, and potentiallycatastrophic impact. It’s actually quite simple:greenwash threatens the whole business rationale forbecoming more environmentally friendly. Greenwashis slowly eating away at the best part of the greenbusiness case.The opening chapter of this guide revealed thehuge temptation of greenwash: the growing greenpound. In a free market economy this ‘consumerdemand’ is actually more influential than governmentpressure, campaigning groups’ demands or even thecompany directors’ own self-interest in preservingthe environment. What the market demands themarket often gets, and focus groups and marketresearch demonstrating growing market demand forgreen products have driven the innovation and shifttowards green by many major companies. You’reasking for and buying green products, so companiesare making them. If you stop, so will they.If you’re an ‘environmentalist’ type of person adverts for ‘eco-friendly’SUVs are obviously annoying, but why do we get so much more upset aboutgreenwash than the thousands of adverts that happily and legally try to sell usunsustainable products?A truly rational approach would surely rail against adverts for disposablenappies, cheap flights, water-polluting detergents and obesity-causing fastfood. There’s far more money spent on advertising those destructive productsand services than on greenwash.Destructive forcesGreenwash eats away at that market demand byconfusing consumers and making them uncertainabout buying green products. Eventually they’llstop buying based on their green preferencesaltogether. Greenwash destroys the very market ithopes to exploit.Surveys in the UK and USA show this undermining ofconsumer confidence is well underway. In fact someshow that 9 out of 10 of us are sceptical about greenor climate change information from companies andgovernments14. Half of us in the UK have no ideawhat to believe and 80% want to see companies backup ethical claims with proof15. The same is the casein America. Seven in ten Americans either “strongly”or “somewhat” agree that when companies call aproduct green it’s usually just a “marketing tactic”and therefore to be mistrusted.The continued greening of business requires thecontinuing, compelling business case of marketdemand. The terrible irony is that greenwash mayput itself out of business; by causing consumers tomistrust every green claim, no matter how justified.20
  19. 19. Greenwash is a snappier term, but of courseorganisations also can ‘ethics-wash’ theirproducts and performance. This is basically thesame as greenwash, except that you substituteunsubstantiated or irrelevant environmental claimsfor social or ethical ones.Although much of the research for this guide hasbeen focused on green claims, the reader mayfind help here for avoiding and preventing‘ethics-wash’ too.The Perils of ‘Ethics-wash’Armaments andDefence sector
  20. 20. The marketers’ viewAdvertising agencies have the potential to play anincredibly powerful role in convincing consumersto buy green products, ultimately leading to thegreening of the marketplace. But they are also theoriginators of greenwash. Agencies are both theproblem and the solution, as the authors of thisreport, an agency ourselves, well know.We contacted the ten agencies listed by the Instituteof Practitioners in Advertising’s as the top London-based advertising companies:1. AMV bbdo2. JWT3. McCann Erickson4. Publicis London5. Ogilvy6. M&C Saatchi7. DDB London8. Saatchi & Saatchi9. Euro RSCG London10. RaineyKellyCampbellRoalfeSo, what is being done about greenwash by the industry that makes the mostout of it: the advertising agencies that design the adverts and of course thebroadcasters and publications which accept that advertising?During the research for this guide the top 10 advertising agencies in the UKwere contacted, as were the highest profile and largest sellers of advertisingspace. They were simply asked what they thought of greenwash and if theyhave a policy, training or standards on the issue.Each was asked about their response to the challengeof greenwash, whether they have any internal policyon the prevention of greenwash and if they offer theirstaff any training in how to avoid greenwash.Any modern, conscientious industry shouldmanage the environmental issues of its day-to-dayoperations and the advertising industry has taken thisresponsibility seriously: eight out of the ten agencieshave an internal sustainability policy. These policiescover important impacts such as travel, green energyand recycling. But just as a very ‘green’ factory couldbuild a very polluting product, so an agency with verygreen operations can still produce greenwash.Only four of the top ten agencies agreed to commenton their actual product. Of these four, only one hadany plans to extend their current green policy tocover the client side of the business - how productswere advertised. The other three agencies allreadily acknowledged the problem, but said it wasimpossible to not sell a product on its ‘differentiatingfactor’, i.e. what makes it different to the mass ofother products in the marketplace. In the words ofone agency’s Managing Director, “If a car companyhas invented the world’s first hybrid supercar - whichmight still be very polluting - then as an agency, wecould not turn to the client and tell them to sell it onthe free sat-nav instead of the environment”.Clearly there are tough choices for the advertisingindustry, torn between its potential to aid theenvironment and its power to greenwash. Theindustry is in real need of guidance.Perhaps therefore it is the industry’s formal bodieswho are most responsible for pointing the rightdirection. And that is exactly what the CharteredInstitute of Public Relations has recently done.23
  21. 21. PR fights backThe CIPR’s Best Practice Guidelines forEnvironmental Sustainability Communications16are a laudable effort to bring some rigour to thefight against greenwash, but in many ways they askmore questions than they answer. It is imperativethat PR Agencies build their knowledge of technicaland often scientific green issues if current errors ofjudgment are to be avoided. This points towards aneed for more specialisation across the sector and itwill be intriguing to see how the CIPR supports thedevelopment of these new skills into the future. Thetwo other major industry bodies; the Charted Instituteof Marketing and the Institute of Practitioners inAdvertising seem not to have their own guidance fortheir large memberships, although the CIPR lessonmay encourage them to start drafting.Advertising salesSo if not the agencies, then how about thosepublications and broadcasters that are funded byadvertising but still have a responsibility to theirreaders and viewers?Thirty-nine of the major media sellers of advertisingspace were contacted:The TimesThe SunThe Daily Mail / Mail on SundayThe Sunday TimesThe Daily Telegraph / The Sunday TelegraphThe Independent / Independent on SundayThe Financial TimesThe Guardian / The ObserverTrinity Mirror Group (5 national newspapers)The Daily Express / Sunday ExpressOK! WeeklyVogueGlamourHeatWhat’s on TVMarie ClaireRadio TimesHello!Vanity FairElleCosmopolitanRedGraziaEconomistSaga MagazineGood HousekeepingITVChannel 4fiveBSkyBThese 19 national newspapers, 16 of the best-sellingmagazines, and 4 of the UK’s major commercialbroadcasters taken together account for £6.77bn17ofadvertising spending per year. Out of these thirty-nine media outlets, only three (yes, three) had heardof the term ‘greenwash’: one commercial broadcasterand two broadvertsheet newspapers. Not a singlemagazine had heard of one of the biggest, mostrecent trends in advertising. Of course we may haveunluckily picked one un-informed staff member ineach organisation we spoke to and the companiescould all have detailed greenwash policies. But if so,their advertising sales teams don’t know about them.Of these thirty-nine media outlets, only one couldconfirm they had any sort of internal policy or stafftraining in place to avoid greenwash. Once again,it was clear from these calls that very many mediaoutlets are concerned about their ecological impactand are taking steps to reduce it – but this sustainableattitude does not translate into advertising policy.concerned about their ecological impact and aretaking steps to reduce it – but this sustainable attitudedoes not translate into advertising policy.Many publications said they could not foresee a timewhen adverts making misjudged green claims would24
  22. 22. be turned away, with one Ad Sales Manager saying,“To be frank, what needs to happen is that thegeneral public begins to understand that someadverts are environmentally obscene - but let’s faceit, for the moment environmental concern is certainlynot on a par with depiction of violence or nudity”.Asked why they had no policy on greenwash orgreen advertising, many interviewees said, quitereasonably, that their organisation could not beexpected to verify the green claims in every ad theyprint. They simply do not have the time or budgetsfor such a mammoth task - instead, all organisationswere happy to follow the ASA’s lead, and wouldwelcome stronger guidance from the Authority.It seems that both the advertising sellers andcreators are still on the first steps towards an industryresponse or standard for greenwash. Yet they arewilling to start a discussion. There is however, onemissing factor in this: the advertising buyers, thosecompanies and organisations that pay the advertisingagencies to design their adverts and pay the mediaoutlets to display them.Unfortunately calling every company in the countryfor their policy on greenwash was beyond thescope of this report. We have however, managedto interview some brave businesses that have beenstung by criticisms of greenwash, and who areprepared to share their war wounds and learning.
  23. 23. GoodbyegreenwashWhat’s to be done? From ourresearch we’ve learnt it’s quiteeasy to prevent greenwash. Butcompanies, communicationsagencies and consumers will allneed to learn a few new tricks…
  24. 24. British Gas case studyBritish Gas has a long history of positive green action. Theyuse green messaging in advertising and marketing across arange of issues, from new products and services to offeringfree home insulation to the over 70s and those on benefits.As they put it; without advertising how else are people goingto know the offers are there?Although they believe that ‘green’ is still a growingcompetitive issue in the energy market, it has been shownto be one reason why people stay with their providers. AndBritish Gas hasn’t been coy about getting out and tellingcustomers about their commitments.But they haven’t been free of criticism, and their advertisingfor a ‘Zero Carbon Tariff’ (a green energy and offset product)was pulled up by the ASA for being potentially misleading.At the time British Gas responded to the ruling, by arguingthat they had the independent evidence to support theirclaim. Their evidence demonstrated that customers arefamiliar with the ‘zero-carbon’ terminology and wouldn’tfind it misleading (of course all activities have some carbonfootprint – even breathing). Their assertion that they hadthe greenest energy tariff had been based on a comparisonof green supply offerings from the independent groupEnergy Watch.They still feel that it’s important for the ASA to see claimsfrom a customer perspective rather than simply a rule-based one, but they have gained some important insightsfrom their experience. Firstly that the word ‘green’ is fartoo subjective and that companies should be as specific aspossible (hence British Gas focus on low carbon emissions).Avoiding caveats is also important - too many asterisks orbrackets and you lose both the power of your marketingmessage, and also the understanding of your audience.It’s also crucial to make sure the lines of communicationbetween your creative team and your legal team are open.These two groups don’t always speak the same languagebut when it comes to environmental claims they may have tolearn translation.Finally, British Gas recommends that companies only usegreen messages when they’re helping their customersunderstand something or offering them something new. Ifyou’re too insular you might forget the perils of greenwash.
  25. 25. Six easy steps forcompaniesStep 1:Know thyselfBefore even starting to think about a green marketingcampaign: work out if you’re green or not.Pick the products or services you wish to promoteon green grounds with care, and beware of yourcompany’s overall reputation in the area (you couldbe making energy-saving light bulbs while pollutinglocal rivers).Knowing yourself will help you avoid three easymistakes;• Firstly, take care when promoting a single greenattribute of a product when the rest of the productis not e.g. bio-degradable packaging around anenergy-inefficient product.• Notice when creative teams get excited bylearning you’re the greenest ‘in your class ofproducts’, remember if your ‘class’ is that of superheavy SUVs then consumers might laugh you offthe stage.• Relevance has already been touched upon; beaware that consumers might be dubious of boldclaims about a ‘dolphin-friendly’ chicken pie ora ‘CFC-free’ product (being as CFCs have beeneffectively banned since 1989)One of the mistakes we’re not going to dwell uponis deliberate lying. If that is your intention then weapologise if the title of this greenwash guide wasmisleading: we’re not here to help with that. Ourpresumption is that most greenwash is perpetrated inignorance or over-enthusiasm, not out of mendacity.Of course that type of greenwash does exist, and thisreport advises agencies and consumers on how tospot it. But simply telling you not to be naughty isn’tgoing to make much difference is it?Step 2:Be green by design, not luckIf after Step 1 you realise you’re not as green as youthought then you’ll need to innovate. The easiestproducts and services to promote responsiblyare those specifically designed to be green orre-designed to be so, not those where you havesearched for a green aspect. ‘Green by design’products are likely to have undergone a full ‘life-cycle analysis’ of the impact of their source materials,through manufacture and distribution, impacts ofuse and finally how they affect the environment onceready to be disposed of.Step 3:Check and check againOnce you’ve got something worth talking about, youneed to make some checks. Many companies bring inexternal experts to help design green products, or totest an ‘eco-redesign’ of current products. Of course,there are those much neglected internal expertsas well: your ‘Sustainability’ or ‘Corporate SocialResponsibility’ team. If you are a FTSE 100 companythese fonts of knowledge and experience on greenissues are there already, but other companiesincreasingly have internal experts. Not only are theylikely to be your harshest critics (they know themouldy green skeletons in the company closest),they can also provide audited data on your overallcompany footprint.Search out both these internal and external expertsand ask their opinion before embarking on greenpromotions.The learnings from British Gas’ experience (supplemented by others whowish to remain anonymous) uncover some simple steps that can be taken bycompanies, agencies and the public to stamp out greenwash.28
  26. 26. Step 4:Choose your friends wiselyInviting third parties to endorse your product (in theform of labels and respected organisations’ logos) isa powerful indicator to customers of your integrity.Don’t be tempted by easy options or half-heartedinitiatives. The big labels are hard to reach and that’sexactly why they are trusted.Now you’re ready to plan a campaign. In a reportwritten by a specialist green communications agencyit might seem pushy to say ‘choose your agency withcare’. But if you seem to know more about the issuethan your agency, it would be wise to check their copy.Step 5:Remember words can hurt youLong gone are the days when ‘eco-friendly’ or ‘non-toxic’ would cut it. Some terms like ‘organic’ nowhave legal definitions and others (such as Fairtrade)are copyrighted. If you like the following terms,take care to justify what you mean by them, and if indoubt, contact the ASA’s free Copy Advice Service.Examples of goodcertification schemes.Clockwise from topleft: Kitemark®,Marine StewardshipCouncil, ForestStewardship Council,the FairtradeFoundation and SoilAssociationEco-friendlyNaturalNon-toxicGreenPollutant-freeCarbon neutralEthicalFairRecyclableLow-impactEnvironmentally friendlyEnergy efficientLow carbonNot tested on animalsCleanZero carbonZero wasteDon’t forget that images can also give a misleadingimpression. A poster showing flowers coming outof a oil refinery stack very well may be consideredmisleading (yes, it did happen).29
  27. 27. Step 6:Greenwash health checkAlthough your campaign might be rigorous in itsclaims, don’t forget that greenwash can pop upacross your communications, from advertising, viaCEO speeches or PR, to your product packaging.It’s a good idea to health-check all channels forgreenwash infestation.Communicationschannels susceptibleto greenwash30
  28. 28. Three even easier steps forcommunications agenciesStep 1:Be clearDevelop a clear agency policy on greenwash andtrain your account teams and creatives on the easymistakes that can be made. Have an escalationprocess for them to raise concerns or questions tomanagement.Step 2:Make some new friendsIt’s also a good idea to secure a green advisor or twowho can check claims. People who have worked forpressure groups (and have scientific qualifications inthe subject) are excellent at this, and also ratherenjoy it.Step 3:Stand up and be countedBut remember to let your clients know your policy inadvance. It’s never fun to have to point out ‘that wedon’t do greenwash I’m afraid’ after you’ve alreadybeen commissioned. Publish your policy and they’llknow to go elsewhere for dirty tricks. Of course, weall find ourselves in difficult positions sometimes, butif you’ve taken Step 1 then your staff will know it’sOK to say ‘no’.But together we canThe Climate Group’s campaign Togetherhas been called “the best inoculation againstgreenwash”. This is a consumer campaign(and label) that companies can join if theymeet certain criteria:• Firstly the company has to sign up tothe Climate Group’s principles anddemonstrate a credible policy forreducing their own emissions• Together campaigns must promotea solution or product that has ameasureable impact on reducing carbon• The solution must be a new initiative (butnot necessarily new technology). Theygive the example of Marks and Spencerre-labelling their clothes to take accountof green issues.• Finally, and most importantly, a Togethersolution has to make climate actioneasier, cheaper or more appealing forcustomers.If a company can meet these criteria thenthey can use the Together logo on themarketing for that specific product. Thepower of Together is that it’s never usedfor companies, only for ideas and productswhich help you, the consumer, reduce yourown carbon footprint. Keep an eye outfor it.31
  29. 29. Wiping away greenwashCharacteristics of greenwash33
  30. 30. Wiping away greenwashCharacteristics of good claims34
  31. 31. 15
  32. 32. A virtuous orvicious cycleSo what can we expect in the coming monthsand years from the greenwashers? Fromour research and interviews here are a fewpredictions on what we’ve got coming, boththe good and bad.Cyber greenwashThe Advertising Standards Authority covers obvious advertsand PR, but what about the blogs, virals and wikipedias of cyberspace? One of the least pleasant forms of greenwash around iscalled ‘astroturfing’, and we’re likely to see more of it. Accordingto said Wikipedia, ‘astroturfing’ is:“The term is a wordplay based on ‘grassroots democracy’ efforts,which are truly spontaneous undertakings largely sustained byprivate persons (not politicians, governments, corporations,or public relations firms). ‘AstroTurf’ refers to the bright greenartificial grass used in some sports stadiums, so ‘astroturfing’refers to imitating or faking popular (‘grassroots’) opinion orbehaviour.”Watch your mouseOnline ‘astroturfing’ means quotes from the public, blogswritten by interested individuals, spontaneous email chains,and yes, even Wikipedia pages that seem to be put together by
  33. 33. ordinary folk, but which in fact are the careful creations of PRfirms hired by greenwashers. A moment’s thought shows howwidespread this could be.Luckily, surveys prove that we grade online information as theleast trustworthy of all types. Keep your greenwash antennaeextra sensitive online and check the sources of all pseudo-sounding science or green claims.How long until the first green ‘spam’ email? Actually, it’sprobably already happened.Global standardsThe International Standards Organisation has their own greenclaims code, yet a number of national governments have feltthe need to develop their own. Cultural differences, greenawareness levels and even political affiliations all affect how asociety judges greenwash.It seems likely that greenwash will begin to raise questions atan international level. National governments may even considerpenalising national companies who greenwash overseas.Raising the barThe good news is that with a growing market comes growingcompetition, and we are all likely to be offered more specificallydesigned green products, and much greener versions of oldfavourites. If we buy them we’ll get even more.However, this opens up a risk for business. A product that looks‘pretty green’ in 2008 might just look like greenwash by 2009.
  34. 34. A greener futureIf we project the current speed of growth in green consumption in the UKthen the ‘green pound’ could be worth £53.76bn in five years and nearly£180bn by 2022. That kind of market is going to have a real and lastingpositive impact on the planet and probably make us all a bit happier.14
  35. 35. But if greenwash follows a similar trajectorythen a tipping point will soon be reached. Toomuch greenwash and we’ll stop buying basedon companies’ green claims. That will crushthe greenwash threat, but take the chance forconsumer-led green market revolution with it. Withall that that means for eco-systems, the climate andour quality of life.The authors of this report prefer a second vision.We hope consumers will punish greenwashersthrough avoiding their products, advertisingagencies will refuse to work for them and mediaoutlets won’t take their adverts. Instead we all willeagerly buy, and buy again, the products with good,justifiable green claims. Soon greenwash is a termout of history books and a positive feedback loopbegins the long slow climb to an eco-friendlymarket place.And yes, we know we just used ‘eco-friendly’. Sorry.39
  36. 36. Learn moreDefra and DTI: Green Claims – Practical Guidance:How to Make a Good Environmental Claim,November 2003Forum for the Future and Business for SocialResponsibility: Eco-promising: Communicating theenvironmental credentials of your products andservices, April 2008TerraChoice: The 6 Sins of Greenwashing, November200740
  37. 37. End notes1Accountability and Consumers International:What Assures Consumers on Climate Change?,p.23 (June 2007)2The Co-operative Bank: Ethical ConsumerismReport 2007, p. 103BBC News: “British organic food sales soar”,22 December 2005 (Source: Mintel in-houseresearch, 2005)4The Co-operative Bank: Ethical ConsumerismReport 2007, p. 25Ibid.6The Guardian: “The rise and rise of the ethicalconsumer”, 6 November 2006 (Source: Ipsos-Morisurvey, 2006)7Admap Magazine: “Green is the Colour”,December 20078Concise Oxford English Dictionary, 10th Edition9US Environmental Protection Agency website10Defra and DTI: Green Claims – Practical Guidance:How to Make a Good Environmental Claim,November 200311Australian Competition and ConsumerCommission: Green Marketing and the TradePractices Act, February 200812 Bureau de Vérification de la Publicité: “Pourune publicité éco-responsable et une nouvellerégulation professionnelle”, 11 April 200813Norwegian Consumer Ombudsman’s Office:Use of Environmental Claims in the Marketing ofVehicles, 3 September 200714 Accountability and Consumers International:What Assures Consumers on Climate Change?,p.23 (June 2007)15Ethical Corporation, “Greenwashing – consumersgetting wise”, 14 November 200716Chartered Institute of Public Relations: CIPRBest Practice Guidelines For EnvironmentalSustainability Communications, March 200717Advertising Association, 2007Disclaimer: The text of this Greenwash Guide reflects the intellectual opinion of Futerra following our research, and not the views oropinions of other third parties. We have endeavoured to afford all interviewees and participants the most transparent process of interview;all interviews were carried out with the participants’ full knowledge of the end-use of the interview material.The presence of the FairtradeFoundation, Marine Stewardship Council, Soil Association, British Standards, and FSC marks does not imply that those organisations arein any way supportive of, connected to, or have authorised, the text and images in this booklet. The logos for the Climate Group and theTogether campaign are printed as an illustrative means of showing our thanks only. None of these three organisations have endorsed, orare connected to, the content of the Greenwash Guide; nor is our use of the logos meant to imply that this is the case.Art direction, design and illustration: Futerra.Photographs on cover and inside front cover by Bonnie Lo. All other photographs from iStockphoto.
  38. 38. About the AuthorsFuterra is a communications agency. We do thethings great agencies do; have bright ideas,captivate consumers, build energetic websitesone day and grab opinion formers’ attentionthe next. We’re very good at it.But the real difference is that since ourfoundation in 2001, we’ve only ever workedon green issues, corporate responsibility andsustainability.Futerra is extremely thankful for help andadvice from:The UK Advertising Standards AuthorityThe Climate GroupBritish GasAnd all those who respondedto our market research calls.For more information onour services, or to see ifwe could help you, or call+44(0) 207 549 4700To find out moreinformation aboutgreenwash please