I’ve been holding back on laying into the third and latest Sins of Greenwashing report – in part because I’m feeling too much like a broken record – but I’ve got to weigh in.
The report, if you’re not familiar with it, is published by TerraChoice, a Canadian-based environmental marketing agency. (Earlier this year, it was acquired by UL Environment, a division of Underwriters Laboratories. GreenBiz is engaged in a partnership with UL Environment that is wholly unrelated to TerraChoice.) TerraChoice’s report aims to take stock of the state of greenwashing — that is, false and misleading environmental marketing claims made by companies — based on a survey it conducts in 24 stores in the U.S. and Canada. This year’s survey covered nearly 5,300 products that made some kind of environmental claim. All told, more than 12,000 claims were evaluated.
TerraChoice uses a seven-part screen to judge the claims. Any product that failed to pass any one of the seven screens – “sins,” as TerraChoice calls them – was deemed to be greenwash.
The verdict: 95% of the products failed the test. Nearly everyone, according to TerraChoice, is a sinner.
This, believe it or not, is an improvement over last year, when over 98% (of about 2,200 products) were greenwash, according to TerraChoice. In 2007, the first year of the report, 99% (of about 1,000 products) failed. That, it could be said, is progress.
So, what’s my beef? Simply put, the report may be as much of a greenwash as the products and companies it is criticizing.
Want proof? I put the report to its own test. Here is my assessment of the report weighed against three of TerraChoice’s seven “sins.”
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The Sin of No Proof “is an environmental claim that cannot be substantiated by easily accessible supporting information or by a reliable third-party certification,” according to TerraChoice. By that measure, the report fails the test. Its findings do not include supporting information -- it offers only high-level, unsubstantiated findings -- and were not vetted or verified by an independent third party. You have to take the authors' word for it. Any marketer who takes that approach with their products is dubbed a greenwasher by TerraChoice.
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The Sin of Vagueness is committed when a claim "is so poorly defined or broad that its real meaning is likely to be misunderstood by the consumer.” You know: generic, meaningless words that sound good but lack a legal or generally agreed-upon definition, like "natural" or "nontoxic" -- or "greenwash." So, is it an overly broad misuse to cry “greenwash” if a company, say, made a valid marketing claim but failed to adequately back it up? (Fully 70% of all products examined by TerraChoice committed this sin.) After all, "greenwash" was originally coined to describe much more egregious practices – e.g., the "dissemination of misleading or false information designed to make an organization or product appear more environmentally friendly than it actually is" or "the unjustified appropriation of environmental virtue," to cite two reasonable definitions. Neither describes the aforementioned “sinner” that simply failed to provide adequate proof of a valid claim. Hence, TerraChoice is using the same kind of sensational but vague terminology it rails against in its report.
- The Sin of Irrelevance results from an environmental claim “that may be truthful but is unimportant or unhelpful for consumers seeking environmentally preferable products.” This irrelevance cuts both ways. Did TerraChoice apply the greenwash label to companies whose product claims are factually true but insufficiently substantiated? We don't really know, because TerraChoice won't say, but to the extent that it did, this seems unimportant and unhelpful to consumers trying to make good, green choices. In a word: irrelevant.
The tally: I’ve found reasonable grounds that the TerraChoice authors violated at least three of the seven screens it set for green marketers. According to its own rules, a commission of even one “sin” qualifies as “greenwash.”
I’ll admit to some subjectivity here, but that’s partly the point. Many of these things aren’t clear-cut, despite TerraChoice's seemingly definitive pronouncements. For example, I’m guessing that SC Johnson’s Greenlist labels have been deemed by TerraChoice to be greenwash, because they’re self-certified, not verified by an independent third party. True, but SCJ’s Greenlist program — an environmental classification system designed to systematically measure, track, and reduce environmentally problematic ingredients across the company's entire product line — has won a Presidential Green Chemistry Award and accolades from environmental and industry groups. It does not mislead or cover up. I don’t consider it to be greenwash. I’m pretty sure TerraChoice does, however, because it likely commits one of its “sins.”
I say I'm “pretty sure” because TerraChoice won’t say. There are no names named about what specific sins were committed. (See “Sin of No Proof.”)
I asked Scott McDougall, TerraChoice’s president, why his company -- which is so critical of those who fail to be accountable or transparent -- is itself unwilling to name companies or products, or give examples of companies or products that fail to meet its test?
“Our desire is to be constructive, to improve the understanding and quality of claims-making and to focus on shared lessons,” he responded. “It is already difficult enough to get media to use the study this way. To name names would distract entirely and would encourage, we suspect, a witch hunt.” He placed the burden on others — the U.S. Federal Trade Commission, for example — to “identify culprits.”
Naming “culprits” is one thing. Giving concrete and instructive examples that illustrate what TerraChoice considers greenwash is another. Even anonymous or disguised real-life examples would help readers understand what greenwash looks like, and would provide a level of confidence that what TerraChoice calls greenwash meets some reasonable standard. (Did I mention that the word has no legal definition?)
It’s also worth pointing out that there’s more than a little self-interest going on here: TerraChoice (and UL Environment) is in the business of both creating green product standards and selling claims verification services to product manufacturers. As such, the company is not an innocent, independent bystander here. It has a vested interest in fanning the flames of what it dubs the “significant problem” of greenwash. To the extent that marketers get spooked, they’ll need TerraChoice’s help.
Of course, I don’t really consider the “Sins” authors to be greenwashers. I know McDougall and the other principals behind the report and consider them to be earnest, ethical, and committed individuals. The “sins” they have committed, at least by my reckoning, don’t brand them as evil. They are, at worst, publicity-seeking entrepreneurs seeking to differentiate their brand in an increasingly competitive environmental marketplace.
That is to say: They are green marketers.
I’m afraid that those who read TerraChoice’s report won’t be quite so charitable when it comes to rendering judgment on the universe of green-marketing “sinners” that have been universally tarred by TerraChoice’s brush.
I wouldn’t blame shoppers for ending up more confused and cynical than ever. And I wouldn’t be surprised if some companies thinking about touting their green innovations and achievements decide to go back into their shells, keeping mum.
And that would be the biggest sin of all.


















































































































Terrachoice is a for-profit
Terrachoice is a for-profit company that created a bias marketing campaign to push Ecologo (the logo they manage). My wife bought some Ecologo products a while back and noticed greenwashing on the labels. What a farce...that makes Terrachoice hypocrites! This prompted me to check out Ecologo standards. I was surprised to learn that they are so old they cannot really represent environmental leadership anymore?! Others only have a single criterion statement; where is the life-cycle approach they promised on their website?! Check out their website and download the standards and see for yourself... Shame on Terrachoice for pointing the finger at others, when they cannot deliver. Most eco-labels are not worth paying extra money, because we have no idea of the environmental savings. All we have here is hypocrisy, marketing spin, and a very bad marketing campaign. It’s all a scam. Beware!
Joel, Thank you for your
Joel,
Thank you for your thoughtful assessment of the TerraChoice report. While I agree in essence with all that you say about TC violating their own rules, I believe nevertheless that it is important to understand some of the key points in the report.
For example, the information on false eco-labling is critical for consumers to get a hold of. Just because there is a 'certification' label on a product, that still means little in the long run if there are not clearly recognized and understood certifiers. The plethora of false and misleading 'certifications' and 'seals of approval' undercuts the credibility of all legitimate certifiers and creates real confusion among consumers.
Perhaps the UL example is a questionable one to use given TerraChoice's association with them -- but in fact UL labeling has been an important part of the evolution of trusted electronic products for safe use in a household. Consumers almost universally knew who UL was and that their certification meant something.
Question the report, sure. But don't forget that there is still meaningful and useful information in it as well.
I wanted to comment on Joel's
I wanted to comment on Joel's defense of SC Johnson's Greenlist Program. It may be an award winning program but it is nonetheless misleading. I provide public seminars on greenwashing and one of my slides displays the Greenlist logo. When I ask the audience what it is or what it means they unanomously associate it with a third party verification program and are surprised to find it is self-certification. Today with the many third party verifiers that provide transparency in environmental claims why wouldn't SCJ improve all their products across the board (rather than distinguish the harmful from the safe) and certify the products that achieve standards known to the scientific and environmental community. What if all companies used SCJ's approach?
Thanks for this thoughtful
Thanks for this thoughtful article, Joel. SCS is also in the business of verifying environmental claims, so to some extent we benefit from consumer confusion of green claims as it encourages companies to seek certification. In the bigger picture, however, we see a larger benefit when marketers leverage their products' or businesses' environmental performance to build strong brands. The “sin” report is of concern in that it may turn companies off of green marketing and could stifle the movement as a whole.
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I love your willingness to
I love your willingness to publicly address the TerraChoice report in this way - I've always been bothered by the report's own lack of concrete data disclosure and broad-brush approach. Consumers would do well to remember that, as you point out, the "Sins of Greenwashing" is an actual marketing piece - not a peer-reviewed study. That it might be represented as anything else is, indeed, misleading.
This is not to say that the information it contains is not valid or helpful - and I tend to agree with Don that the report will, in the end, encourage companies to look more closely at their claims rather than clam up. I think there's just too much momentum in the private sector's love affair with "green" products and services to turn back.
And therein lies the rub: my biggest concern is not so much that consumers will stop believing "green" is worth paying for, nor that companies will stop talking about it. Rather, my fear is that we'll simply continue talking about "green" as a fuzzy, feel-good concept and fail to delve deeper into the actual on-the-ground implications of such practices and products.
I realize that UL's work is primarily in standardizations and certifications - but I want to see more metrics, more units of measure that we can use to evaluate these claims. That's the basic principle behind SDAP (which focuses on a particular industrial supply chain). But for that kind of transparency and clarity to happen, there has to be both cross-sector and cross-company collaboration.
Which brings me to Don's point that "both you and TerraChoice are asking for more than the law requires." That's true. But ultimately, it's absolutely critical that companies (and their marketers) do go beyond mere compliance.
I hear a lot of people complaining about how regulation is not a solution - and in and of itself it's not. But companies would do really well to realize that compliance is a very low benchmark - and that if they really want to innovate and carve out markets, they ought to be working with regulators to help develop better benchmarks and better metrics, so legitimate data sharing and disclosure can actually happen. That's how consumers (and companies) will be able to make sense of claims and, more importantly, impacts.
Fortunately, I heard this sentiment reinforced over the last few days from many companies that are diligently trying to figure out how best to do this (at the Net Impact Conference in Ann Arbor, MI).
So while it's certainly flawed in its own way, TerraChoice's report at least offers a beginning framework for evaluating claims. It certainly doesn't do it perfectly, but let's take it with a grain of salt and use what we can from it to inform our next steps - actual, real metrics.
Thanks Joel! TerraChoice
Thanks Joel!
TerraChoice has constructed a definition of greenwashing that fits with its business goals as architects and administrators of the Canadian EcoLogo system and whatever other certification program that they may engage in with UL Environment. I share your concerns that that the TerraChoice definition may be too broad, too vague, too subject to my view versus your view.
Maybe it's time to pause for a bit on throwing the greenwashing term around since there isn't a shared definition of the term and, maybe even more important, a shared approach to how marketing claims are evaluated. Perhaps the green marketing community should set up a process for developing a definition for greenwashing and methods for evaluating green marketing claims that are robust enough to meet consumer expectations and regulatory concerns globally.
Great points. I doubt many
Great points. I doubt many consumers actually read these reports or even hear of them, and doubt their real impact on the marketplace. Their real effect is likely in helping/pushing brands to communicate more clearly - including back up of self-certifications (an approach I wholly support where high integrity standards and audits are used).
You raise some good points.
You raise some good points.
I agree that the "Sins" report would have been better if it had included anonymous or disguised real-life examples to help readers understand what the greenwash they are referring to looks like, and provide examples of brands that are marketing without committing green sins.
I also agree with your conclusions that “Sins” authors at Terrachoice may be entrepreneurs seeking to differentiate their brand in an increasingly competitive environmental marketplace, and that they are not greenwashers. Overall they have been above board in their efforts and have done a great deal to raise awareness of the pervasive use of vague and misleading green marketing claims.
If the public loses faith in advertising, the integrity of markets is eroded and the entire economy suffers… especially the nascent green economy. Legitimate marketers lose sales to competitors when unscrupulous advertisers make false, misleading or unfair advertising claims.
The recently published results of the FTC's Green Guide consumer perception study confirms that vague and misleading environmental claims have become a growing problem. The results of this are doubly devastating when false, misleading or unfair environmental benefit claims are allowed to proliferate… the public and the environment stand to lose.
Finally, I agree that some companies will decide to keep mum if they fear that they might be 'tarred' as greenwashers, but I do not believe that brands making credible innovations will be deterred from making environmental benefit claims. Rather, I believe that increased scrutiny will help to discourage unscrupulous marketing tactics and level the playing field. This will provide advantage to firms that qualify and substantiate their green marketing claims.
Regarding the Sin of No Proof, both you and TerraChoice are asking for more than the law requires. It is important to note that while Section 5 of the FTC Act does requires that prior substantiation of marketing claims must exist, it does not require that the substantiation must be published. That being said, advertisers have both legal and ethical responsibilities to advertise truthfully. In addition, advertising agencies, public relations firms and design firms who develop marketing materials have a duty to make an independent check on the information used to substantiate marketing claims.
Consumers and advertisers who believe that brands are making misleading or unfair claims also have a right and a responsibility to take action accordingly by making their specific complaints known to the FTC or to the Better Business Bureau. They can also register their concerns about "greenwash" in response to the FTCs recently issued request for public commentary on its revisions to the Green Guides for marketers making environmental benefit claims. Interested parties can submit their comments in paper form by following the instructions in the “Request for Comment” section of the Federal Register notice or they can submit comments electronically at:
https://ftcpublic.commentworks.com/ftc/revisedgreenguides/
Don
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You make a good point. Those
You make a good point. Those who judge others for their transparency, forthrightness, etc. aren't necessarily role models themselves. The adage about taking your own medicine really still applies.