It’s a fine line between Green Marketing & Greenwashing

Imagine you are a marketing professional working for a hotel provider which has recently installed solar panels in 50% of their properties. You know that customers and investors are increasingly looking for environmentally friendly options and you are keen to share the hotel brand's green credentials. So, you decide to launch a new ‘Greener Stays’ campaign and your design team sets to work on a beautiful green lotus flower logo with supporting nature-inspired images. You promote the campaign across your website and social media, whilst also sending personalised emails, thanking customers for choosing a ‘Greener Stay’.

One week after the campaign goes live, you start to receive accusations of greenwashing - you feel alarmed and a bit baffled, surely this is just positive marketing you didn’t set out to deceive anyone and with solar energy now powering 50% of the hotel’s properties, the customer’s hotel stay is now greener – right?

Before answering the question above, we need to better understand greenwashing. The Cambridge dictionary offers the following definition:

“behaviour or activities that make people believe that a company is doing more to protect the environment than it really is””.

This definition can be interpreted or applied differently which perhaps partly explains why 40% of the nearly 500 websites included in The International Consumer Protection Enforcement Network (ICPEN)’s annual sweep (where websites across many sectors are analysed for their environmental claims) appeared to use tactics that could be seen as misleading and possibly in breach of UK consumer laws. Recognising the need for clearer guidance in the UK the Competition and Markets Authority (CMA) introduced the Green Claims Code in 2021.

The Green Claims Code

The code is a list of six key principles designed to prevent businesses from making misleading environmental claims to consumers in the UK about their products and services.

CMA Guidelines:

Claims must be truthful and accurate.
Claims must be clear and unambiguous.
Claims must not omit or hide important relevant information.
Comparisons must be fair and meaningful.
Claims must consider the full life cycle of the product or service
Claims must be substantiated.

Beware! Claims can also be implicit.

Environmental claims encompass more than just language. Visual elements like imagery and colours can also convey environmental impact meaning. For example, pairing natural colours with nature-inspired imagery suggests a product has a lower environmental impact. It's vital to consider these implicit messages in environmental claims.

Greener Stays = Greenwashing

So back to the scenario ... whilst we know that our hypothetical ‘Greener Stays’ campaign was never intended to deceive, it is sadly an example of greenwashing and here is why:

The campaign implies that all the stays with this hotel company chain are greener when in fact only 50% of the properties now use solar energy. It only considers one aspect of the hotel company’s environmental impact, ignoring their policies on, for example, single-use plastics, waste, or water management. This makes the campaign unclear and ambiguous. While this is just a hypothetical example, we have actual cases where companies have been required to change their approach. Last year Booking.com took it’s ‘Travel Sustainable’ program offline, following concerns raised by a regulator. More than 100,000 properties on its site had been awarded a sustainability score between 1 and 3 represented by green leaf icons. The Netherlands Authority for Consumers and Markets said: “It implies that traveling and staying at one of the program-affiliated accommodations are sustainable, even though this is incorrect,” the regulator found. “The use of the green leaf reinforces this implication.”
Many of the hotels featured in the “Greener Stays” campaign were in long-haul destinations that require a flight to the destination. By promoting the stay as sustainable (which is implied in both the campaign language and the visuals) it’s fair to assume that customers would interpret this as meaning their entire holiday is greener when in fact the installation of solar panels will do little to negate the environmental impact of their flights.

Eager to respond to the backlash, you reach out to your hotel client for more detail on the use of their solar panels. You publish an apology, acknowledging that the campaign was considered misleading, and to clarify that your intention was to highlight the steps that the hotel business had taken to reduce reliance on fossil fuels. You are pleased to share that their properties with solar panels have reduced carbon emissions by 80% year-over-year. With a sigh of relief, you turn your attention to the next campaign. However, just two days later, you find yourself at the centre of a new social media storm with fresh accusations of greenwashing.

Once again, these accusations prove to be well founded and here’s why:

Your supplier made a great choice by installing solar panels, but they did not account for the full life cycle of the solar panels in their calculations. The production, shipping, and installation of the panels generate emissions, creating a CO2 "debt". It will take a variable amount of time for the panels to generate enough electricity free of environmental cost to "pay back" this initial CO2 debt.
When calculating the reduction of carbon emissions resulting from the use of solar panels, the hotel chain based their average on just three destinations, selecting locations heavily dependent on fossil fuels where the panels would have the greatest impact. This approach does not provide a fair and meaningful comparison, nor does it represent their entire portfolio of properties.

Scrutinise your suppliers’ claims.

When a business supplies products or services to another for resale or incorporation into other products or services, both parties may be liable for false or misleading environmental claims. Businesses should ensure they can provide evidence about the environmental impact of products or services from others in your supply chain. To effectively scrutinise your supplier’s claims, it’s essential that you have a strong grasp of the legislation surrounding environmental claims.

Legislation in the EU and activism.

The EU is setting the regulatory bar higher than the UK. On 22 March 2023 , the European Commission published its proposal for the Green Claims Directive. This directive aims to establish a consistent framework for companies to substantiate their environmental claims with verifiable evidence, requiring third-party verification before these claims reach the market. Non-compliance could lead to severe penalties, including exclusion from procurement processes and fines of up to 4% of annual turnover. Even if a business is not based in the EU, the Green Claims Directive would apply to its communications if directed at EU consumers. Meanwhile, activists are increasingly focusing on unsubstantiated environmental claims and tourism businesses are in their sights. The Advertising Hunters, currently ranked number 6 on the Sustainable 100 list of top citizen initiatives (with Extinction Rebellion at number 1), are leading this charge. Acting now to train and support your staff on best practices will ensure your sustainable communications comply with EU law and avoid negative publicity.

More legal challenges will follow.

We can expect more legal challenges and scrutiny of the terminology in common use. For instance, there is an argument that the term "sustainable aviation fuel" (SAF) , a term used and understood by academics, governments, fuel companies, and the energy industry, constitutes greenwashing. While SAF offers great potential to significantly reduce net greenhouse gas emissions compared to fossil derived jet fuel, it does not eliminate green house gases and may emit an equivalent amount of carbon when burned in flight. The use of the term "SAF" is at risk of legal challenge unless it is explained to consumers that SAF still has negative environmental impacts.

Silence is not the answer.

Sharing sustainable initiatives holds the power to inspire and accelerate change. But brands who fear the backlash and reputational damage from accusations of greenwashing often choose not to share their achievements. This phenomenon, often termed “green hushing”, is as detrimental to progress, as greenwashing. Communicating your sustainability credentials should always be encouraged but marketing teams need to be equipped with the knowledge, confidence and evidence to support their claims. Marketing teams have the opportunity to rise to the new challenge of building their professional expertise. So, watch this space for a future piece featuring examples of travel companies leading the way in authentic communication.

Act now.

Irresponsible business practices can mislead well-meaning consumers who want to make informed choices, can divert funds from truly responsible options, and undermine consumer trust.

Sustainability isn't just a marketing tactic; it requires authentic commitments and responsible actions. With heightened legislation and stricter enforcement around environmental claims, greenwashing can lead to costly litigation and fines, harming both a business’s finances and reputation.

Avoid accusations of greenwashing by observing UK consumer laws and following the Green Claims Code if you are selling to customers in the UK, and by observing EU legislation if you are selling to customers in the EU. You must be able to substantiate your claims, and provide your teams with the necessary data to focus on facts and build trust in your brand, whilst, if you are selling in the EU, preparing your business for compliance with the upcoming Green Claims Directive.

To find out more about how Terraverde can support with matters of greenwashing and sustainability, please click here to visit their profile.

TerraVerde is the sustainability consultancy for travel and tourism. Our expert team provides practical, business-friendly advice to support clients at every stage of their sustainability journey. We help implement effective strategies aligned with global standards, navigate pathways to certification, ensure regulatory compliance, conduct risk assessments, and reduce consumption and costs; all while fostering trusted communication.