What’s Greenwashing & How to Avoid It?
Across industries, with pressure from multiple stakeholders, brands have been looking to align or demonstrate their products as sustainable. Aviation faces parallel pressures from customers, owners, financial institutions, insurance providers, and employees to be more sustainable as an industry. Labels and certifications are key ways to help compare company commitments and demonstrate responsibility. However, the rush to tout commitments can introduce opportunities for claims to be misleading, exaggerated, or unsubstantiated.
Enter Greenwashing
Greenwashing is the practice of making a product or company appear to be more environmentally friendly or less damaging than it actually is. Greenwashing does not have to be intentionally deceptive; it is usually done by mislabeling, using vague language, environmental imagery, or leaving significant information in the fine print. If a typical consumer would be misled or not given an accurate picture, it can be perceived as greenwashing.
Greenwashing can result in legal action by regulators, investors, or consumers. Recently, Delta Airlines and other airlines in Europe have faced legal action from consumers who claim that using carbon credits to offset emissions is insufficient to claim an airline is “sustainable.” In the case of Delta, the allegations claim that using “the world’s first carbon-neutral airline” is misleading and that a particular type of carbon offset project used by the airline is unreliable for actual permanent reductions.
How to Avoid Greenwashing - Best Practices
Taking some basic steps can help prevent becoming the victim of public backlash or, worse, a lawsuit around accusations of greenwashing.
| Suggested Messaging | Messaging to Avoid |
|---|---|
| "XYZ Operator is Carbon Neutral Through Verified Carbon Credits" | "XYZ Operator is Environmentally Friendly" |
| "In the Last Year, We Used 10,000 Gallons Of Sustainable Aviation Fuel (SAF)" | "We Operate Only Using Sustainable Aviation Fuel (SAF)" |
| "We Counterbalance the Emissions of All Our Flights Through Verified Carbon Offsets*" | We Are a Green Charter" |
| "XYZ Operator Offsets Every Charter Flight Using Verified Carbon Credits*" | "We Are Carbon-Free" |
| *Flights are calculated based on origin, destination, and aircraft type using ICAO's carbon intensity for jet fuel |
First, avoid broad or vague claims. Most activities have some level of environmental impact. Regarding claims about an organization's sustainability, it’s best to qualify claims by stating that the sustainability is relative to a baseline or widely accepted standard, usually the status quo. Avoid using exaggerated comparisons that could be construed as misleading. Steer clear of using headlines like "Fly Green," "Fly Sustainably," or "The Leading Environmental Aviation Operator,” which can mislead the reader into thinking there’s no environmental impact by using the advertised services.
Be careful in claiming that your organization is “sustainable.” Rather, talk about how it is “more sustainable” and through what methods it is achieving those improvements, what the improvements are, and based on what standard or calculation model those improvements are calculated. Be transparent in every part of a claim: what part of your organization is included (are you including every flight or just ones with customers onboard?), the specific claim (how much are you reducing emissions rather than claiming to be the greenest operator), how it is achieved (are offsets or SAF used?), the model used and standards or baselines referenced (are you using your baseline or an ICAO one?). Lean towards oversharing when marketing around sustainability commitments or achievements.
Disclose the scope of emissions covered by the claim. Where in the lifecycle are the emissions being offset or reduced? It’s a critical distinction to prevent a misleading statement or an incorrect claim. Sustainable Aviation Fuel (SAF) is a great example. The fuel does not reduce emissions produced by the jet engines but instead uses feedstocks that aren’t extruded from the ground, adding less carbon to the atmosphere. SAF is produced using carbon already in the atmosphere, so it only reduces emissions over the fuel's life cycle. Any claims around reductions from SAF need to identify this.
Along the same vein, be clear about what scope of the operation is covered by the claim. For example, if a company only covers flights with customers onboard, that should be disclosed. Or attention has been raised about whether a program covers the beginning and end of life of an aircraft as well. It is best to disclose how far the life cycle analysis goes, whether direct and indirect emissions are covered, and what exact scope of the operation is covered.
For accurate emission reductions, it is essential to use the correct calculation method. To minimize risks, companies should disclose the methodology employed in computing emissions for the claims made. There’s no shortage of carbon footprint calculators from both the public and private sectors. While the difference may seem minor, the results and estimates could vary widely. Use actual data when possible and use leading industry standard calculators or carbon intensities to ensure standardization. Providing full transparency and citations on the methodology used to arrive at the figures helps remove any doubt about an organization’s logic.
Disclosing whether emission reductions are like-for-like. If claims about methane emissions are instead made on a carbon dioxide equivalent basis using offsets based on reductions in other Greenhouse Gases, companies should consider disclosing that fact to mitigate greenwashing risk. For example, using offsets to compensate for the impact of contrails or non-CO2 emissions should be disclosed differently than reducing the emissions directly.
Understand the terms being used. Carbon neutral and net-zero carbon have different meanings and convey different levels of commitment. Using incorrect language can be an easy way to overclaim or make a statement that greenwashes.
Lastly, consider using a third party to verify commitments and partnering with an organization that can take an unbiased approach in assessing the claims made. Utilizing an outside organization knowledgeable in sustainability best practices adds to the claims’ validity and can insulate the organization.
What Regulators Are Saying
As sustainability becomes increasingly important to investors and consumers, various regulatory agencies outline guidelines and regulations on communicating sustainable practices. Regulators are very keen on what terminology is used to convey an organization’s commitments to sustainability, down to the specific use of phrases such as “zero emissions,” “zero carbon,” or even “environmentally friendly.”
In private litigation, failing to follow the standards in the Green Guides may provide evidence for false advertising claims under state law, including in cases where the language used in the claim is not directly addressed by the Green Guides.
In the US, the Federal Trade Commission (FTC) published the Green Guide , a Guide for the Use of Environmental Marketing Claims with guidelines and principles to avoid greenwashing. The Green Guides help companies determine whether marketing statements about the environmental benefits of goods and services would be misleading to consumers. The U.S. Federal Trade Commission (FTC) has requested comment on whether to retain, modify or rescind the Green Guides, which were originally issued in 1992 and last revised in 2012. Comments were due April 24, 2023.
Qualifications and disclosure: All qualifications or disclosures should be clear, prominent, and understandable, using plain language and large type. To achieve this, disclosures should be placed in close physical proximity to the relevant claim, and distracting visual elements should be avoided.
Distinction between benefits of product, package, and service: It should be obvious whether the sustainability claim refers to the product, the product packaging, a service, or just a part of those elements.
Overstatement of environmental attributes: Sustainability marketing claims should not be overstated directly or by implication. Ecological benefits that are insignificant should not be stated or implied.
Comparative claims: Any comparative claim should be clear and supported by substantive information to avoid confusing consumers.
In the UK, the Competition and Markets Authority (CMA) has established principles to follow when making claims about environmental sustainability.
Claims must be truthful and accurate: Consumers should be able to make informed buying decisions. Claims should not be misleading, contain incorrect information, or give a false impression about the company’s sustainability efforts. They must meet the claims about their products, services, brands, and activities.
Claims must be unambiguous: Consumers should be able to easily understand the claims meaning the claims should not leave any room for misinterpretation or confusion. The meaning of the messaging and the credentials of the product should be aligned.
Claims must not omit or hide important, relevant information: Companies need to share all information on environmental impact, which consumers need to make an informed decision; no relevant information should be withheld.
Comparisons must be fair and meaningful: Comparisons with other products or brands should not be misleading and should be based on objective, recent, and clear information. Comparisons should only be made between products intended to meet the exact needs and purpose.
Claims must consider the full life cycle of the product or service: The entire business’ activities must be taken into account when making sustainability claims, including its supply chain. The overall impact of a product of service needs to be reflected instead of only one specific aspect of the business.
Claims must be substantiated: They should be backed up with robust, credible, and recent evidence supporting them.
Other countries and regional regulators are working on their own guidelines and rules for advertising sustainability claims. In March of 2023, an EU Commission adopted a proposed “ Directive on Green Claims.” Meanwhile, Australia has also drafted guidance to “improve businesses environmental claims.” Regardless of the regulating body, there are similarities between most of the guidelines and policies, communicating in a manner that is transparent, accurate, fair, and comprehensive to someone who is not directly familiar with the industry is key.
Don’t Shy Away, Be Cautious
An organization shouldn’t be discouraged from advertising or making public claims about its environmental sustainability programs or commitments. However, careful consideration should be taken to review the language and claims being communicated. Greenwashing rules are governed by the country you are advertising in, not the country you are based in, so take care to understand local jurisdictional rules around advertising sustainability claims as well.
The biggest piece of advice is to be transparent. Be transparent about how the organization is reducing emissions, are they reductions in direct emissions through more efficient aircraft or life cycle reductions from the use of SAF, or are carbon offsets being used to counterbalance the emissions produced? Make sure that key information is not hidden, and that additional information is easily accessible for readers.
Sustainability programs bring premium value or a competitive advantage between similarly offered services or goods. It will be a key part of aviation operations in both attracting customers and advertising aviation to the public. However, care needs to be taken to be honest about the progress that has been made and how sustainable the options are that are actually available to customers. Sustainability is a journey, particularly for aviation, and we don’t want to falsely advertise that we are already at the end of that journey.