It’s only greenwashing if you intend to deceive. Right?

Greener Stays or Greenwashing?

Imagine you are a marketing professional working for a Tour Operator, your largest hotel provider 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 your brand’s green credentials. So, you decide to launch a new ‘Greener Stays’ campaign and your design team set 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 green marketing you didn’t set out to deceive anyone and with solar energy now powering 50% of the properties the stay is now greener – right?

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

“to make people believe that your company is doing more to protect the environment than it really is”

This definition is vague, 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 2021the Competition and Markets Authority (CMA) introduced the Green Claims Code.

The Green Claims Code

The code is a list of six key principles[PR1]  designed to prevent businesses from making misleading environmental claims about their products and services.

CMA Guidelines:

  1. Claims must be truthful and accurate.
  2. Claims must be clear and unambiguous.
  3. Claims must not omit or hide important relevant information.
  4. Comparisons must be fair and meaningful.
  5. Claims must consider the full life cycle of the product.
  6. 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 messages. 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 = Greenwash

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:

  1. The campaign implies that all the hotel stays in this chain are greener when in fact only 50% of the properties now have greener energy. It only considers one aspect of the hotel’s impact, ignoring policies on single-use plastics, waste, or water management, which may have worsened in the past year. This makes the campaign unclear and ambiguous. Earlier this year Booking.com took its ‘Travel sustainable’ program offline. More than 100,000 properties on its site had been awarded a sustainability score between 1 and 3 represented by Greenleaf icons. The Netherlands Authority for Consumers and Markets said“It implies that traveling and staying at one of the program-affiliated accommodations is sustainable, even though this is incorrect,” the regulator found. “The use of the green leaf reinforces this implication.” 
  2. Many of the hotels featured in the “Greener Stays” campaign were in long-haul destinations that require a flight to be viable on an average 10–14-day holiday. 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 impact of their flights. Last month it was ruled that TUI had violated the Dutch Sustainability Claims Code by attempting to make long-haul holidays look sustainable by making non-flying elements greener.  

Eager to respond to the backlash, you reach out to your hotel provider for more details on the positive impact of their solar panels. You publish an apology, acknowledging that the campaign was considered misleading, and clarify that your intention was to highlight the significant steps your supplier had taken. 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:

  1. 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 impact of the 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 to another for resale or incorporation into other products, both parties may be liable for claims and must substantiate them. To do so, businesses should ensure they can provide necessary substantiation, this will likely involve obtaining evidence 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.

Heightened legislation and activism.

The EU is setting the regulatory bar higher than the UK. On March 12 of this year, the European Parliament approved the proposed Green Claims Directive. This directive aims to establish a consistent framework for EU 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 UK and 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 a strong argument that the term “sustainable aviation fuel” (SAF) constitutes greenwashing. Many now prefer to call it “biofuel” because, while it offers great potential to significantly reduce emissions due to its greener life cycle compared to fossil fuels, it emits an equivalent amount of carbon when burned in flight. The term “SAF” is likely to face legal challenges soon.

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. Green marketing should always be encouraged but marketing teams need to be equipped with the knowledge, confidence and data 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.

Addressing greenwashing is essential because it damages real progress being made in making tourism more sustainable. Irresponsible businesses mislead well-meaning tourists, 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 lawsuits and fines, harming both a business’s finances and reputation.

Avoid accusations of greenwashing by consistently following the Green Claims Code, substantiating your claims, and providing your teams with the necessary data to focus on facts and build trust in your brand, whilst preparing your business for compliance with the upcoming Green Claims Directive

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