As more and more people become conscious of the environmental impact of their purchasing behaviour, the issue of “greenwashing” (false or exaggerated environmental claims intended to convince consumers of the company’s green credentials) has achieved prominence over the last few years. The issue has in fact been largely driven by the media and public debate; the number of complaints received by SROs about this issue remains low.

Most of these complaints relate to car advertising and the use of environmental claims such as “green”, “environmentally friendly”, etc. This reflects an increase in public concern about climate change and global warming, which in turn has led to a proliferation of marketing claims about such matters as fuel economy and CO2 emissions.

On a separate issue, ongoing concern about road safety makes it necessary to ensure that motor vehicles are not marketed or advertised in ways which might, however unintentionally, encourage inappropriate attitudes or lead to careless, inconsiderate or dangerous road behaviour. See Car advertising for more information.

Self-regulatory rules

Environmental claims
All self-regulatory advertising codes prohibit misleading claims and environmental claims are no exception. However, because scientific knowledge is in a state of continuous development, the potential for misleading claims is higher in this area.

The ICC Code includes a separate section on environmental claims. However, prompted by a call from industry stakeholders for guidance on the use and assessment of environmental marketing communications, to safeguard consumer confidence in such claims, the ICC published in 2010 a Framework for Responsible Environmental Marketing Communications.

The framework includes a practical checklist for those preparing marketing communications campaigns containing environmental claims. It also contains a chart providing easy reference to relevant sections of the ICC Code and interpretations on current environmental marketing issues. The framework can be downloaded from the ICC website.

The Framework has the following to say about green claims:
“All marketing communications should be judged by their likely impact on the reasonable consumer, having regard to the characteristics of the targeted group and the medium used. A consumer’s interpretation of a green claim is affected by the context in which it is presented, the level of knowledge and experience (e.g., professional or sophisticated users versus typical consumers), and form in which it is conveyed. As such, a green claim that is scientifically accurate could still be deceptive if it misleads consumers because of what it implies or omits. Moreover, even reasonable consumers may have different interpretations of one claim presented in a particular context. Advertising the environmental aspects of a product often requires qualification and additional explanation, not merely the use of buzz words to attract consumers. As a result, using green claims is a more complex undertaking than many advertisers realize.”

Levels of complaints

There have been few complaints about advertisements containing environmental claims or relating the advertised product or service to environmental sustainability, whether in words or pictures. A slow increase can however be noted with complaints reaching an avarage of 3.43% of all complaints across European self-regulatory organisations in 2008.