As society moves towards a more conscious and sustainable way of life, consumers are increasingly opting for products that are less harmful to the environment than others. Making informed purchasing decisions, however, can be a challenge, especially with greenwashing, and the increasingly prominent trend, greenhushing, on the rise. When most of what consumers know about a product comes from the hangtag or other product displays, how much do they really know? How much of this information is helpful? And how much of this information can be confusing or even misleading?
By using buzzwords like ‘green’, ‘eco-friendly’, or ‘sustainable’, companies attract consumers that believe the products they are purchasing are good for the planet. The problem with these claims lies in the lack of data-based backing. These vague claims of ‘eco-friendliness’ are made without substantiated data, which can be considered greenwashing.
In 2020, the European Commission launched an exhaustive study related to sustainability claims¹, which showed that 53% of claims provide vague, misleading information about the products’ environmental characteristics. Of these claims, 40% could not be substantiated. Moreover, 230 sustainability labels and 100 green energy labels were identified, and half of them offer weak or non-existent verification. Findings like these have triggered heightened enforcement amongst consumer authorities and other institutions and have signaled the need for new legislation to curb greenwashing.
Last year, various greenwashing lawsuits made headlines in the fashion industry. Several major brands were sued and/or publicly scrutinized by consumer authorities or consumer groups for misleading claims. In the past year we also saw the removal of H&M’s Conscious label and Zara’s Join Life label. Similarly, Asos decided to remove their Responsible Edit range and filter from their website. Additionally, the Sustainable Apparel Coalition (SAC) decided to pause its consumer-facing transparency program after the Norwegian consumer authority found it to be ‘misleading’ consumers.
In a popular trend, an increasing number of fashion brands are choosing to disclose less about their sustainability efforts and the sustainable attributes of their products in a new phenomenon called ‘greenhushing’. A 2022 report by South Pole² details three potential reasons behind this shift: fear of failure, fear of scrutiny, and fear of litigation. While it makes sense for the industry to tone down and avoid misleading or generic claims, silence is not the answer as it can slow down progress towards a collective sustainable fashion culture. In fact, less public-facing communication limits knowledge-sharing to industry peers and consumers – which could result in missed opportunities for collaboration and engagement. It could also give the impression that sustainability leaders are failing to lead, at least in the public eye. This is concerning: now more than ever, we need those making headway on sustainability targets to inspire others to make a start, and to help shift mindsets and behaviors. That said, the industry needs to establish very clear rules on what it means to make ethical sustainability claims so consumers (and industry peers) can be properly informed, and not misled.
Harmonized guidance is coming
In Europe, new regulation is being drawn up to protect consumers from greenwashing. One of the pillars of the EU Strategy for Sustainable and Circular Textiles is promoting consumer-facing transparency. Within this context, on March 22nd, the EU Council launched the proposal for a Directive on Substantiating Green Claims³ to tackle greenwashing by ensuring the accuracy of companies’ green claims.
According to the proposal, when companies choose to make a ‘green claim' about their products or services, they will have to respect minimum norms on how they substantiate these claims and how they communicate them. Claims will need to be independently verified and proven with scientific evidence (adopting a ‘life-cycle assessment’ approach); and if products are compared with others, these comparisons must be fair. Claims or labels that use aggregate scoring of the product's overall environmental impact shall not be permitted and, to avoid the proliferation of environmental labeling schemes, new private schemes are only allowed if they can show higher environmental ambition than existing ones⁴. The final legislation is expected to be launched in 2024.
In the US, the Federal Trade Commission (FTC) will soon launch the last update of its Guides for the Use of Environmental Marketing Claims to help businesses avoid misleading claims. At the moment, FTC is soliciting public comment on the update, and the American Association for Footwear and Apparel (AAFA) has suggested to allow qualified environmentally ‘sustainable’ product-level claims if two conditions are met:
- The claim does not imply the product or product components are wholly environmentally sustainable; AND
- A statement immediately precedes or follows the environmentally ‘sustainable’ claim that includes specific information about the environmental impact(s) that underly the ‘sustainable’ claim.
The challenges of making substantiated green claims
To be able to communicate sustainable improvements, the information provided to consumers must be truthful (clear and relevant); transparent (proven with scientific evidence); and backed by a robust, third-party verified system. Achieving this, however, is not without its challenges.
The first challenge is deciding how these concepts can be further defined, and deciding what the new regulation will consider acceptable. In an ideal world, we would have primary, third-party verified and comparable data (collected and analyzed according to the same methodology) from every step and process in a product’s supply chain which includes the use phase and end-of-life. This information could then be compiled and tallied to reflect the product’s total impact. It could also be used to make accurate comparisons between products. The problem? Carrying out a life cycle assessment (LCA) is still a costly and time-consuming process, an investment that not all supply chain actors are able to make. For this reason, the industry’s access to primary data from their own supply chain is limited and instead mainly relies on secondary data and averages from databases that don’t always accurately reflect the impact of ‘that specific product’. To top it all off, not all sustainability parameters are currently covered under the LCA method, including recyclability, biodiversity and microfiber shedding.
In the end, crafting an accurate, substantiated and comprehensible claim is no easy feat, and is wrought with challenges like limited data availability and data quality. There are potential challenges on the consumer side as well. Businesses and industry leaders must ask themselves: will consumers even be able to understand and process all this complex information when buying products?
Moves to increase transparency & to put an end to greenhushing
Despite the challenges, there is an industry-wide effort to effectively tackle greenwashing. There is, needless to say, ample room for improvement. Textile and fashion industry players like Recover™, a leading mechanical textile recycler, welcome clear and pragmatic regulations to not only produce more sustainable products, but also to share this progress in an ethical way.
Recover’s communications and claims, for example, are created based on third-party verified LCA studies which are performed according to PEF methodology. Recover™ provides guidelines and support to customers and brand partners on how to accurately craft consumer-facing communications about Recover’s recycled cotton. To make this sustainable data ‘user-friendly’, Recover™ highlights impact savings in relatable terms like ‘number of showers’ or ‘wash cycles’. Given the limited space to communicate these savings (hangtags, for example, can usually only include one or two short claims), Recover™ includes QR codes that redirect consumers to a webpage with more information about the savings and the LCA behind them. These small steps, collectively, can make a huge difference and help increase transparency and combat greenhushing.
¹ European Commission. (2020) Circular economy: New rules on substantiating green claims (Green Claims Directive). Available at: https://environment.ec.europa.... (Accessed: 28 May 2023).
² The South Pole Team. (2022) Net Zero and Beyond: A Deep-dive on Climate Leaders and What's Driving Them. South Pole. Available at: https://www.southpole.com/publ... (Accessed: 28 May 2023).
³ Directorate-General for Environment. (2023) Proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive). Available at: https://environment.ec.europa.... (Accessed: 28 May 2023).
⁴ Directorate-General for Environment. (2023) Proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive). Available at: https://ec.europa.eu/commissio... (Accessed: 28 May 2023).