You’ve decided certification isn’t for you, but you’re still doing good things for people and planet that are worth sharing. How do you communicate them without misrepresenting or being accused of greenwashing?
Maybe there isn’t a certification that fits your specific product or sector, or the actions you’ve taken, or it’s simply too costly for your small business to afford.
That certainly doesn’t mean you shouldn’t talk about your efforts!
This is article 2 in a series about certifications and claims. Check out part 1 on choosing the right certification for your business and part 3 on building credibility to support your claims.
Why it’s worth communicating your sustainability claims
Talking about sustainability is one of the 4 critical components of the small business sustainability framework, the HERO Method. We don’t want to greenwash, but we also don’t want to greenhush! It’s important that sustainability efforts are visible in order to raise awareness of sustainability and encourage others to take action, while also being honest and authentic.
Even if your efforts are imperfect or incomplete, if you’re going beyond business as usual to try to be better, it’s important to talk about that journey. This allows your customers and employees to support your efforts, providing some return on your investment whether reputationally or financially. It’s also a good opportunity to seek their input and feedback on your plans, building stronger relationships and trust.
This applies even if you have a certification – good communication is still important!
Different types of claims and when to use them
But how can you approach it? There are generally three approaches to communicating environmental performance:
Type I: Third-Party Certified Eco-Labels (ISO 14024)
Type II: Self-Declared Environmental Claims (ISO 14021)
Type III: Environmental Product Declarations (ISO 14025)
We spoke about type I in the previous article. It’s the best option when a recognised label is useful or you’re looking to win public or corporate tenders.
Type II, self-declared claims, is a good place to start for small businesses who might not be able to afford certification or are working towards it, or there simply isn’t one that fits your product. They do carry less trust since they aren’t externally verified, but are ok to make as long as they are supported by evidence and not misrepresented.
Type III is mostly used for higher levels of rigour and transparency required within certain supply chains like manufacturing inputs and construction materials. They offer a comprehensive view of the life cycle and are best for customers with technical expertise.
We’ll cover both type II and III below.
What is greenwash?
According to the ACCC, greenwashing describes environmental claims that are false or misleading, especially ones that represent a product, service or the business itself as better for or less harmful to the environment than it really is.
Greenwashing includes both intentionally misleading statements and visuals and inadvertent misrepresentation, as well as misleading by omission.
Below are some specific types and examples of greenwash to beware of:
- Vagueness – e.g. calling something green, clean, environmentally friendly, eco-friendly, sustainable, earth friendly or safe (note, the ACCC specifically calls out these troublesome words, so beware of using them!)
- Irrelevance – advertising actions that are mandated by law, such as ‘CFC-free’, or otherwise standard practice in your sector/product category
- Immateriality – advertising improvements in one aspect while ignoring the product or business’ far more significant impact
- False labels – designing something that looks like an ecolabel but doesn’t have any third party standard behind it
The ACCC released a fantastic guide in 2023, Making environmental claims: A guide for business to help businesses navigate the do’s and don’ts with lots of examples. I highly recommend checking it out.
How to talk about your sustainability efforts
So now you know what not to do – so what should you do instead?
Often sustainability claims look like a single statement in your advertising, product page, packaging, or social media. This is separate from, but should be backed up by, broader discussions and narratives of what you’re doing as a business, and the same principles apply to both.
The ACCC guide sets out 8 principles for trustworthy environmental claims, but a few of them overlap, so I’ve grouped them into 3 overarching themes for simplicity.
These same principles also apply to social claims such as ethical sourcing, community impact and employee wellbeing.
Be clear, specific and accurate
The most important thing when making a claim is to focus on exactly what you’ve done, not broad adjectives. Don’t say you’re eco-friendly, say exactly what makes you better for the environment than your peers or than the way you did things in the past. Use plain language and define any important terms.
Focus on the actual actions you've taken – just the facts, ma’am – not vague ambitions and plans. Clearly state any limits on scope or boundary, like only one product line or site, or only head office not the product supply chain.
State quantities, such as the percentage reduction in energy use or packaging or the percentage of renewable or recycled material. If you don’t know the quantity, the claim probably isn’t solid enough to make. Also state what specific chemicals you don’t include, the specific origins of the materials you do, or the specific product, competitor or year you’re comparing against.
ACCC principles – 1. Make accurate and truthful claims, 4. Explain any conditions or qualifications on your claims, 5. Avoid broad or unqualified claims, 6. Use clear and easy to understand language, 7.Visual elements should not give the wrong impression
Back it up with evidence
Before making any claim, check – what are we basing this on? Is there clear data supporting it? When it comes to any marketing claims – not just environmental and sustainability ones – a claim that isn’t supported by evidence is false advertising.
This evidence could be data you've collected, lifecycle assessments, or credible scientific studies, and also needs to cover anything you're comparing to, like your competition or past formula. If you’re saying something is better for the environment, provide the scientific basis for how.
Don’t say something without knowing you can back it up and make sure you can defend it if anyone were to challenge. Even better, provide a weblink or QR code to a product page or sustainability page with further details so anyone who is interested can check it themselves!
ACCC principles – 2. have evidence to back up your claims. The ACCC may only have one principle on this, but it’s probably the most critical of all!
Be open, authentic and accountable
This is something businesses of all sizes frequently get wrong by only talking about the positives. Showing only one side of the story is greenwash.
No one expects you to be perfect, so don’t try to look like you are. Be honest about where you are along the journey, the gaps of where you’re not perfect, what you’ve tried that hasn’t worked, and where you’ve fallen short on your goals and how you plan to adjust.
This is not just important to avoid misrepresenting your performance, but also builds trust and relatability with your customers. An analogy I often think about is of a fitness influencer on social media – if you see someone who looks too perfect, for whom it looks easy, it’s not terribly interesting. But if they show you their struggles, are relatable, get you invested in their success, then you’re much more likely to buy in!
One other thing the ACCC points out is that talking too much about future plans can also give a false impression, so make sure they have clear timelines and action plans to back them up.
ACCC principles – 3. Do not hide or omit important information, 8. Be direct and open about your sustainability transition
Making climate claims
One common area of environmental claims that is especially fraught is climate and carbon claims. Many businesses are actively trying to reduce their impacts, but the terminology can be difficult!
“Carbon neutral” means all greenhouse gas emissions have been “offset” by an equivalent amount either removed or avoided. This term and approach has become increasingly criticised because a business can merely pay for action elsewhere without changing its own operations. The idea of ‘neutral’ or ‘offset’ are easily misunderstood by consumers to mean the business has no impact, which it still does.
“Net zero” refers to a more stringent approach to reducing emissions as far as possible before neutralising the small residual amount that cannot yet be eliminated. This is why most businesses have a target to achieve net zero, as it is significantly more advanced.
“Climate positive” (sometimes called “carbon negative”) means that the business offsets more emissions than it generates. It sounds good but is about as wishy-washy as carbon neutral as it does not require any reductions and there is no widely accepted definition or threshold to achieve ‘positive’.
The same principles as above still very much apply here. Don’t rely on these vague terms, but be specific about exactly what you’re doing, focusing on actual reductions first. Back up any emissions reduction statements with transparency on your actual emissions data and boundaries, actions taken, and how much you’ve purchased in credits, including details of the projects.
Making recycled content claims
Another common area of environmental claims is recycled content. A few terms that are important to understand here are:
“Post-consumer recycled” (PCR) is material made from items that have been used and discarded by consumers. This is what your average person thinks of when they see ‘recycled’.
“Post-industrial recycled” (PIR) (sometimes called “pre-consumer”) is material made from manufacturing waste or scrap that is redirected back into manufacturing without going to consumers first. If the material comes from an outside waste stream, such as a separate company where it would have gone to waste, this may still be considered recycled content if the source is clearly stated.
“Virgin content” is newly extracted material used in manufacturing for the first time.
When making a claim of recycled content, it is important to specify the actual percentage and source in your pubic statements, as well as maintain records of every stage of the material’s journey (chain of custody).
How to phrase your claim depends on how the content is measured and combined with any virgin material.
The role of ISO 14021
ISO 14021 Self-declared environmental claims sets out definitions and methodologies for key terms such as recycled, recyclable, compostable, renewable material, etc. It is a useful reference to ensure you are making claims accurately.
Businesses can also get their products third-party verified against the standard by organisations such as UL, Intertek SAI Global and SGS, which is a good option when you want to show credibility to your customer but there isn’t an ecolabel that fits your product. This is now a requirement in the EU.
In Australia, a new National Framework for Recycled Content Traceability has also been released that sets standards for market chain of custody, collection and sharing of information, so it is also important to be aware of it if supplying within that market.
LCAs, EPDs and DPPs (oh my!)
It’s also worth quickly touching on the third type of claim noted above, Environmental Product Declarations (EPDs).
An EPD is a document that communicates quantified environmental impacts using a standardised format to enable comparability. It takes the outputs of a Life Cycle Assessment (LCA), such as GHG emissions, water depletion, ecosystem loss, and ozone depletion, and presents them as prescribed by specific Product Category Rules (PCRs).
EPDs are most relevant for government procurement, major developments pursuing Green Star or Infrastructure Sustainability (IS) certifications, and materials transparency for manufacturing supply chains.
It is also used to inform the Digital Product Passport (DPP), a digital information card required for products sold in the EU.
6 steps to make a claim
To pull it all together, here’s a step-by-step approach to making sustainability claims that you can follow to ensure you’re sharing your progress appropriately.
1. Identify what you’ve done that is different from your peers
If you’re going beyond business and usual and making efforts to improve against the industry standard, that’s worth sharing. But if everyone else in your industry is doing the same thing, it’s irrelevant.
2. Collect data
Before you make any representations about your performance, make sure you have evidence to point to. You may have installed a water-saving device, but do you know it’s actually reducing your water use? You’ll need to collect the data from your water bills or other metering before and after its installation, or find credible industry data or LCAs to compare to.
3. Look at your achievement in context
Are there other parts of your business that might be a more significant area of environmental or social impact? This doesn’t mean you shouldn’t talk about the good things you’ve done in a different area, you’ll just need to be transparent. If you’re not sure, you can look at industry guidance and certifications for your sector and what they focus on.
4. Draft your narrative
Outline what you’ve achieved, using specifics like real metrics, actions taken, and any boundaries of what parts of your business or product range it applies to.
5. Stress test your statement
- Are there any vague terms that aren’t clearly explained?
- Could this be misinterpreted?
- If someone challenged this, can we confidently back it up with evidence?
- Are we transparent about the gaps and the journey in progress?
You may also wish to run it through a greenwashing checker tool online, such as Sustainability Tracker’s Compass. Document the review in case of any future concerns.
6. Provide further detail for reference
You don’t want to overwhelm the casual reader, but you also want to provide the details to those who are interested. Consider providing a hyperlink on product webpages or QR code on packaging to get the details behind your statement and learn more about your efforts.
Credibility in practice
You don't need to be perfect to talk about sustainability, and you don't need a certification to do it credibly. What you do need is to talk about your efforts in a way that is clear, specific, evidence-based and honest about where you are on the journey. Whether you're sharing a small improvement or a major achievement, your goal isn't to sound more sustainable than you are; it's to help your customers understand the genuine steps you're taking and why they matter.
In the next article in this series, we'll step back from individual claims and look at the bigger picture of how to build credibility and trust in your sustainability efforts over time.