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Greenwashing, And How to Avoid It


A sustainable advertising industry which is fully supportive of a sustainable economy will never produce work that makes misleading environmental claims. This extract from the new book, Sustainable Advertising, by the Advertising Association's communications director Matt Bourn and Ad Net Zero Chair Sebastian Munden, considers the importance of taking every step possible to avoid greenwashing.

Greenwashing is advertising that carries misleading environmental claims, and it is a serious issue. An issue that could damage public trust in the genuine sustainable claims that brands make. It is essential that, as an industry, we promote our clients in totally open, honest, and transparent ways so that we can preserve the public's trust in our work. Greenwashing not only erodes trust towards advertising (thus, reducing overall advertising effectiveness) but could even discourage companies from promoting their green initiatives, in fear of being labelled "greenwashers." This is a topic that we need to get right.

As we will explore further in this book, sustainability can deliver significant commercial value. It might be tempting to overstate claims in advertising or marketing, and it could be easy for a business to fall into the trap of greenwashing, at the expense of integrating sustainable change into their strategies and throughout their operations. An advertising professional could be encouraged to support or even enhance these claims to achieve better sales results.

Greenwashing may be unintentional or well-meaning, a misunderstanding of sustainability, for example, caused by a disconnect (or lack of integration) between the sustainability and marketing departments in a business. Or it can be intentional, overstating sustainability credentials to win business or to divert attention from bigger environmental damage.  While intentional greenwashing is clearly more unethical than accidental, the aim of our industry must be to eradicate greenwashing in all its forms; from the audience perspective, a misleading advert is a misleading advert whether intentional or not.

Whatever the motivation, as we all strive to play our part in the net zero transition, and as the regulatory framework around advertising sustainable products and services becomes more rigorous, everyone must up their game to eradicate misleading environmental claims.

Given the scrutiny of our industry around the issue of global warming and in a world where customers increasingly demand transparency and environmental responsibility from brands, being challenged on environmental claims is inevitable.

So, as a responsible advertiser or marketer, what do you do? The answer is that, when making environmental claims, you should prioritize efforts to ensure they are accurate, substantiated and contextualized in accordance with the rules.

When you're planning a big global or regional multi-country campaign, it would be wonderful if there was a single set of rules you could follow to make sure all your environmental claims in your advertising are sound. You'd simply come up with your copy or treatment, run it past this "central" set of rules with the help of the lawyers, and move on to the next stage of getting that work out there. Unfortunately, things don't work like that when it comes to rules around making environmental claims. While there are broad principles which are useful internationally, the rules are specific to each jurisdiction you're advertising in. This means the approach you take will ultimately be multinational, not international.

The best starting place is to understand the big picture. Several organizations have produced useful global guidance to help people working in our industry navigate this complex area.

For example, the World Federation of Advertisers (WFA) published their "Global Guidance on Environmental Claims" back in April 2022 which has support from environmental experts from self-regulatory organizations around the world, including the ASA.

Another international source that you might find useful as you think about how to make sure your work is not greenwashing is the Internationals Chamber of Commerce's (ICC) "Advertising and Marketing Communications Code." Chapter D of this code covers environmental claims.

The ICC code is a full-length code of practice and is used as the basis for self-regulatory codes in a number of different countries, including France, Belgium, and China. But while the ICC code is another useful starting point, we can't say that if an ad follows the code, it will be fine in all countries in the world. You'll also need to look at both self-regulatory codes and local laws in each individual jurisdiction.

The ICC has published a helpful guidance framework to accompany its code, covering complex areas such as general "sustainability" claims or specific claims about climate, the circular economy, recyclable content, degradability, and "free-of" claims. This is well worth referring to for practical guidance in these areas.

WPP's Formula For Effective Green Claims

According to Climate Change 2022: Impacts, Adaptation and Vulnerability, The Sixth IPCC Report, consumer behavior change could drive down global carbon emissions by 40 to 70 percent by 2050. It's clear effective green claims can help shift opinion and change behavior at the scale needed to transition to a low-carbon economy. But Ogilvy Consulting identified in its Sustainability Communications Need to Get Real report that more than 60 percent of consumers are cynical about the motivations behind brands' sustainability actions.

In response to this challenge, which is faced by practitioners around the world, WPP launched a new Green Claims Guide in 2022, informed by guidance from regulators such as the U.K. Competition and Markets Authority and U.S. Federal Trade Commission, and underpinned by legal compliance advice.

The guide is designed to help its people ensure that any environmental claims made on behalf of clients that are fair and accurate, and to avoid content that could be misleading in any way.

There are 12 principles of the Green Claims Guide which WPP has given permission to share here:

1. Be truthful and accurate
2. Do not omit or hide important information
3. Only make fair and meaningful comparisons
4. Consider the full lifecycle of the product
5. Substantiate the claims
6. Be specific
7. Be clear and unambiguous
8. Use plain language
9. Do not overstate the benefit
10. Avoid sweeping or unqualified claims
11. Carefully consider imagery
12. Be socially responsible

The Green Claims Guide provides practical tips for account managers, strategists, creatives, and media planners to use from brief to behavior change and is supported by training sessions to give employees the chance to explore real case studies and rulings to help them identify and avoid greenwashing. The guide is complemented by a legal toolkit, which has been incorporated into WPP's legal clearance process.

It followed the internal launch with a client version of the guide in 2023 and offers targeted training focusing on green claims in specific sectors or markets to our people and, where requested, to clients.

This extract from Sustainable Advertising by Matt Bourn and Sebastian Munden is copyright 2024 and reproduced with permission from Kogan Page Ltd. All rights reserved. It can be ordered via the Kogan Page website here and you can save 20 percent when ordering from Kogan Page by using the code ANA at the checkout.

The views and opinions expressed are solely those of the contributor and do not necessarily reflect the official position of the ANA or imply endorsement from the ANA.

Matt Bourn is director of communications for the Advertising Association and Ad Net Zero, based in London, UK. With 25 years' experience, previously he was Managing Director of Braben, working for companies such as Sky, Channel 4, Disney and Sony.

Sebastian Munden is a strategy and communications adviser, based in London, UK. He is also chair of WRAP (The Waste & Resources Action Programme) and chair of Ad Net Zero. He worked at Unilever for 30+ years applying the principles of business as a force for good, lastly as CEO of the U.K. and Ireland business.