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In an effort to minimize consumer eco-confusion, on June 28, 2008, Canadian guidelines were released to help companies and advertisers avoid the sins of greenwash.
Greenwash refers to intentionally or inadvertently false environmental claims about a company or product. The principle behind the updated Canadian guidelines is that companies must be able to back up their claims with respect to the eco-performance of their products or company. The goal is to eliminate eco-confusion and to thereby mitigate concerns that greenwash is causing widespread skepticism and apathy in the consumer marketplace.
Environmental Claims: A Guide for Industry and Advertisers, was developed by the Canadian Competition Bureau in collaboration with the Canadian Standards Association (CSA) and expands on the CAN/CSA-ISO 14021 Essentials standard that was originally released in 2000. This second, more prescriptive edition, has two objectives: to clarify how to apply the standard in practical marketing situations, and to guide industry and advertisers in complying with relevant sections of the Competition Act, the Consumer Packaging Act, the Labelling Act and the Textile Labelling Act.
Indeed, the document clarifies what is absolutely discouraged and how to correctly make environmental claims that are not independently verified by a third party. It recommends against using vague or non-specific claims that imply that a product is environmentally beneficial or benign. For example, an aerosol product should not be labelled ‘ozone-friendly,’ nor should a gasoline product be touted as ‘eco-friendly.’
If you can’t measure it, don’t say it
Words such as green, environmentally friendly, natural and eco- are discouraged because they are difficult to prove without undertaking a comprehensive life-cycle analysis (LCA). Anyone who has tried to do an LCA on any product, or even one ingredient of a product, knows how complex and infinite the exercise is. So the bottom-line is this; claims should only be made where there is a measurable means of supporting the claim and, ideally, this supporting information should be accessible for customer review.
- Sustainable wood
- Better for the environment
- Uses an aerosol replacement that does less harm to the ozone layer
- Uses 20% less energy than our earlier model
- Wood from forest certified to CMA forest management standard
A one-year transition phase
The Competition Bureau recognizes that many, if not all, companies currently making environmental claims will need time to study the guideline and reassess their current advertising and labelling practices. To that end, a one-year transition phase is in place to allow businesses to adjust their environmental marketing statements. In the meantime, the Bureau and CSA intend to embark on an awareness-building campaign to educate businesses and consumers about the guidelines. During this grace period, the Bureau will pursue “egregious cases of deceptive environmental claims” that contravene existing advertising and labeling laws.
International anti-greenwash regimes
Canada is not alone in attempts to resolve eco-confusion in the marketplace. Most countries use the ISO 14020 standard or are developing their own. In the UK, the Green Claims Code, released in 2003, also references the ISO 14001 Environmental Claims Code. Despite this, the UK’s Advertising Standards Authority’s (ASA) 2007 Annual Report described a record number of complaints about environmental claims. When the ASA conducted research about the public’s misunderstandings they found consumers typically failed to read the explanatory text used to explain the claims! Australia, France and Norway have tighter regulations backed by enforceable fines and penalties.
Closer to home, the U.S. Federal Trade Commission is evolving their ‘Green Guides’ through a systematic public consultation, review and update of each section of their comprehensive suite of Guides for the Use of Environmental Marketing Claims. These guides were originally released in 1992, then revised in 1996 and 1998. Current revisions are expected to be complete in the coming year.
In business-to-business, "Analysis Beats Greenwash"
Notably, none of these guidelines directly address the business-to-business marketplace. Perhaps this is because the business-to-business marketplace is distinct from the consumer market. Business buyers by definition should be informed decision-makers. Unlike consumers, they don’t impulse shop and they definitely do read the support statements behind a prospective supplier’s environmental claims. Further still, business buyers and industries have or are in the midst of developing their own environmental criteria for suppliers. In the absence of clear direction from governing bodies, the prevailing wisdom in the b2b world is to stick to performance-based claims. BASF, the world’s largest chemical company, nailed this approach in their “Analysis Beats Greenwash” headline, now used by various BASF business units as their eco-mantra.
Environmental marketing guidelines will continue to evolve with our journey toward a sustainable economy and society. What is acceptable, or even leading-edge thinking today can be outdated or out-of-bounds within a few years. Guidelines such as those put forward by CSA and The Competition Bureau are tools designed to facilitate that journey for companies and buyers.