Greenwashing: keeping it clean

In the UK, we’re lucky enough to regulate our own marketing and advertising. A privilege not afforded to all markets around the world and one we should guard fiercely. Our regulatory body is the ASA – the Advertising Standards Authority and as part of a major marketing consultation in 2021, they are helping highlight the Codes already in place and examining the use of terms such as ‘net zero’ and ‘carbon neutral’.

In a recent session the BPMA held for its members, it highlighted the salient points about how to avoid ‘greenwashing’ in the industry, stressing the point that B2B and B2C are covered by the CAP – Committee of Advertising Practice – Codes. There is a specific part of the Code dedicated to environmental claims (Section 11, available to download via and together with DEFRA’s Green Claims Code and the recent Competition & Markets Authority advice, there is a lot of information out there. In this article, we highlight the areas we feel the industry should be aware of and applying in their communications within the industry and to end users.

The key areas to be aware of when putting your promotional materials together:

  • Understanding of environmental ‘green claims’ is increasing across the general population BUT you cannot assume a level of understanding
  • You must not mislead customers
  • You should hold the evidence relative to your claim(s)
  • Don’t be socially irresponsible

What you should avoid

  • Making unqualified claims
  • Making sure all terms are clear and can be understood easily
  • Absolute claims must be supported with evidence

BUT Comparative claims such as ‘greener’ or ‘friendlier’ can be justified if… the advertised product provides a total environmental benefit over that of the previous product or competitor products and the basis of the comparison is clear.

How do you apply the rules to promotional merchandise?

The BPMA used some examples to illustrate how common expressions could be potentially problematic if not correctly evidenced.

‘Our packaging is 100% recyclable’

You can only say this if it’s true. A recent complaint was upheld as a piece of packaging contained plastic that was not widely recyclable.

‘Our products are making a positive impact on the planet’

You must not give the impression products are greener than they are. For example, focussing on claims that represent a minor positive impact when the main business produces significant negative effects.

‘Our goods are genuinely green forever’

Making statements about the implied claims of the lifecycle of a product mustn’t mislead about the product’s total environmental impact.

‘Our goods are coated in an environmentally friendly film’

‘Our mailing is 100% environmentally friendly’

Thinking about the impact of the product during its lifetime, consider if the application of another product to make something environmentally friendly is in fact the case. You may need to state the damage is less than with other similar products and be prepared to back up the claim. Exaggeration is another big challenge!

What happens if your marketing gets reported?

It’s important to remember just because you are B2B doesn’t make you immune! If someone decides to report you to the ASA, you are likely to be asked to substantiate what you’ve claimed. It takes just 1 complaint to launch an investigation and whilst you may have a complaint that is not upheld, it is still recorded and on public record. And yes, upheld complaints really damage reputations!

In particularly serious cases, you may even be referred to Trading Standards which can carry fines and more.

Clarity on claims you are making is critical

You must base environmental claims on the full life cycle of the advertised product, unless the marketing communication states otherwise, and must make clear the limits of the life cycle.

If a general claim cannot be justified, a more limited claim about specific aspects of a product might be justifiable.

You must ensure claims that are based on only part of the advertised product’s life cycle do not mislead about the product’s total environmental impact.

Do not imply a claim is universally accepted if there is split evidence; for example if you have published a claim and asked a qualified third party to support your claim, and they don’t agree you are not able to state the claim.

If a product has never had a demonstrably adverse effect on the environment, marketing communications must not imply that the formulation has changed to improve the product in the way claimed. For example, if you’ve had a product that has always been eco-friendly you can’t start claiming it has suddenly started saving the planet.

You may, however, claim that a product has always been designed in a way that omits an ingredient or process known to harm the environment.

Recycling claims can’t be a load of rubbish either!

This is all about the evidence. When stating what is and isn’t recyclable it’s critical you do not imply a product is recyclable if they are not. Also take time to understand expressions such as ‘widely recyclable’ really do mean the doorstep recycling or local recycling centres not specialist disposal.

Hold clear evidence you can recycle the product and include clear instructions – end users want to see this level of instruction. QR codes are a great way to link to more information products too. Don’t leave out critical information when considering including a recycling claim – make sure it’s clear and directs the recipient to more information as needed.

If you want to say how much you recycle as a business, you must be able to prove it. A number of large businesses recently have been in the dumps because they couldn’t show clear evidence of what they had been able to recycle despite it being a huge advertising campaign.

Don’t exaggerate the recyclability of the product or the packaging and if you’re not sure, investigate or speak to the supply chain. As we are more aware of what can and can’t be recycled, help customers understand what can be widely recycled so we can make the most of the opportunity at the end of the product’s life.

However, you should be careful that they do not make claims such as “100% environmentally friendly” or “totally recyclable for zero environmental legacy” that cannot be substantiated. Product lifecycle claims can be problematic as they can often be interpreted as ‘absolute claims’ from manufacture to disposal. An absolute claim means it’s understood to be a total truth.

If you describe products as ‘low impact’ or ‘eco-friendly’, you may be indicating some of the materials are recyclable when in fact it’s only part of the product. Take care here as some materials rather than all materials may not represent the true impact of the goods across their lifecycle.

What’s coming in 2022/23 and after COP26

A lot of potentially negative pressure which why its essential the industry doesn’t fall foul of the rules at this stage. ASA are investigating how Carbon Neutral and Net Zero claims are being made – this is being applied to certain sectors first so expect more detailed guidance and ways to uphold the CAP Code coming in early 2022.

What are the BPMA doing about this topic for members?

The BPMA are heavily involved in promoting and educating members and end users about the sustainable opportunities available, plus being part of the Advertising Association’s AdNetZero initiative to positively engage the end user community.

Where can you find information and help?

If you are a BPMA member, you can access support via their website or via the helpful team. You can also ask for free of charge advice on your marketing materials from the Copy Advice Team at CAP, available when you visit under resources.

Other useful sites:

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