You may already be familiar with Defra’s Green Claims Code. For 10 years it has set out best practice on the content of environmental claims including accuracy, truthfulness, relevance, use of unambiguous terminology, presentation of claims and comparative claims.
About a year ago I blogged that Defra was consulting on an update to its guidance - well, the final consultation paper is now published. It is open for comment until 15 June this year.
I will put in a response. I'm very likely to echo the views of the great people at Futerra who have pointed out how toothless the guidance appears to be. (Read also this viewpoint by Fred Pearce in the Guardian).
But in the meantime, a flurry of new rules and guidance has emerged this year to help us understand what more we need to do to promote our green credentials in a way that guarantees greater credibility, consumer protection and social responsibility.
In January the International Chamber of Commerce (ICC) published a framework and practical checklist for Responsible Environmental Marketing Communications (PDF).
The influential Committee of Advertising Practice (CAP) also published its new codes just weeks ago. They bring in additional explicit rules designed to prevent exaggerated environmental promises by products, services and organisations.
The new CAP codes come into effect this September and will be regulated by the Advertising Standards Authority. They state that advertisers must ensure all environmental claims are crystal clear to consumers and all absolute claims must be backed by a “high level of substantiation”. We must acknowledge areas where scientific opinion is divided. We must also base environmental claims on the full lifecycle of the product.
It’s not just about standalone statements in some advertising copy. Linking a single, truthful claim (“we use natural paint to ensure no volatile organic compounds...”) with a broader claim (“Acme Homes are kinder to the planet…”) is likely to get us into hot water. Even a scientifically accurate claim can be misleading if, taken out of context, it implies or omits something relevant.
The rules apply over all paid-for media, and even to websites and social media.
And it goes well beyond what words we use – green claims can include pictures, colours and logos as well.
PR consultants like myself may breathe a sign of relief that, technically, we’re immune - neither the CAP nor the ICC codes apply directly to ‘corporate communications’. We argue that PR about a company’s aspirations and sustainability initiatives, its annual reports or CSR statements are usually provided in a context that will ensure there is no confusion with advertising claims. And anyway, we mutter, the media loves absolutes and hyperbole and has no time for all this qualified language.
However, we would be daft not to take on board every one of these new rules.
It’s not as if it’s all so alien – the Chartered Institute of Public Relations (CIPR) published guidelines on communicating about sustainability two years ago.
Green marketing is no different from regular marketing. Business ethics still hold. Waging war on little green lies will protect corporate reputations, build more confident businesses and counter the cynics out to knock the industry.
10 top tips to avoid greenwash
- If you talk about sustainability, energy, waste, water, raw materials, noise, air quality, global warming, greenhouse gases, wildlife, human health, toxins or other environmental topics in your marketing and PR, make sure you read up on the new codes and international standards like ISO 14021 which clarify requirements on environmental labelling.
- Do an audit. Check the words, the pictures, the colours, the logos.
- Look at everything through the eyes of your most cynical competitor. Then apply what I call the Mum Test (would a “reasonable consumer” understand what this claim really means?)
- Watch out for words like ‘reduced energy’, ‘reduced waste’ etc. Always make it clear what has been reduced. Only make a feature of it if it has resulted in a significant environmental improvement taking all aspects of life cycle into account.
- Verify as much as you can. At the bottom of your advertisements, press releases and marketing literature, provide links to a section on your website where you publish the independent scientific evidence that backs up your claim.
- Not everything has to have a full dossier addressing every conceivable impact of the product on the environment, but the greater the value being placed on the claim, the more robust verification needs to be.
- If you’re planning a major campaign to promote your green credentials, first do some thorough consumer testing and perception research.
- Reassess your claims regularly. Check whether circumstances have changed or what the latest scientific and technical evidence says.
- Communicate the journey, not just the end result. No one expects you to be zero carbon today. But you can gain respect by honestly communicating what actions have been carried out to help you work towards it.
- Make sure your PR, advertising and digital marketing agencies understand the technical details. No more fluff. Demand compliance with the new legal requirements and best practice in communicating about sustainability.
PS. Need more advice? Check out my earlier blog posts on the '10 steps to absolution' from the 'Six Sins of Greenwashing'!