Synthesis

INTRODUCTION

The need for a greenwashing assessment framework

Greenwashing is a form of deception: “any communication that misleads people into adopting overly positive beliefs about an organization’s environmental performance, practices, or products” (Lyon and Montgomery 2015:226). Identifying and combating misleading communication on environmental issues is an urgent and increasing challenge for policy makers and the public alike (Black et al. 2021). Figures such as the Secretary-General of the United Nations identify credible climate pledges amidst widespread greenwashing as a serious challenge to global progress (United Nations 2022). Public concern over the prevalence of greenwashing has demanded refining and tightening corporate social responsibility obligations (Gatti et al. 2019). This has also prompted questions about the role of corporate greenwashing in creating false narratives that confuse and potentially disrupt public demands for regulation (Kolcava 2022). Greenwashing can also reflect other forms of deliberate misinformation, such as climate obstruction: the tactics and discursive strategies used to prevent or undermine global and/or national action on the climate crisis and industry regulation (Ekberg et al. 2023).

Together, these challenges emphasize the need for evolving research “that identifies and catalogs the varieties of greenwash [and] theorizes and models their mechanisms” (Lyon and Montgomery 2015:223). Furthermore, there is a need for work that connects growing academic and popular understandings of greenwashing and their application in practice (Montgomery et al. 2023). The dynamism of greenwashing underlines the need for clear, useful, and constantly evolving tools to help the public and other stakeholders navigate the information environment and the actors implicated in these practices.

Private sector organizations often act as a locus for public discontent and contestation over the ethics of supply chains, labor, and more in what is alternatively described as consumer activism (Lekakis 2022) or political consumerism (Micheletti et al. 2011). Research on green advertising has suggested that corporate environmental communications, particularly advertising, act as an elaborate form of “impression management for an audience of ethical consumers,” making it difficult to assess individual advertisements separately from the company, the industry, or the products themselves (Jones 2019:728). However, greenwashing is not restricted to consumer spheres or commercial organizations. Demands for accountability and transparency from organizations of all types, civil, commercial, political, or other, position critiques of greenwashing within broader communication on and engagement with environmental and political issues (Willis and Schor 2012). The transparency efforts demanded of organizations are closely linked to their promotion and publicity concerns, exposing these powerful organizations to serious critique (Edwards 2020). Conflicts over green claims and greenwashing are exactly these kinds of critique. If greenwashing is “about distraction” (Jones 2019:743), then tools to parse such claims are needed to respond to the proliferation of distractions in public discussions of climate obstruction and environmental performance and solutions. With this article we aim to do precisely that by empirically testing and revising the first interdisciplinary academic and peer-reviewed tool to assess greenwashing (Nemes et al. 2022).

The greenwashing assessment framework: Linking communication research with natural science

In 2022, the Climate Social Science Network’s (CSSN) Spinning Climate Change Working Group, which focuses on the role of public relations in communication about climate change, published an integrated framework to assess greenwashing (Nemes et al. 2022). The greenwashing assessment framework collected and developed metrics for a comprehensive set of definitions of greenwashing, drawing on the expertise of an interdisciplinary team of authors including physical scientists, social scientists, and media and communication researchers. The authors created the framework as a living document to be updated and improved in response to developments in greenwashing research and policy, including feedback from those concerned with greenwashing, such as academics, civil society organizations, environmental policy makers, and professional communication bodies. Since its original conceptualization, the framework has been applied in practical contexts, from classroom use and campus activism, to training for advertising professionals, and to investigative journalism (Institute for Advertising Ethics [date unknown], Teyit [date unknown], trusted by flip [date unknown]). Moreover, new terminology has entered public discourse, including “paltering” (Westervelt 2021) and “nature rinsing” (Supran and Hickey 2022). Globally, new policies and legal processes have reviewed and challenged green claims, particularly in advertising. Together, these developments demand a review and revision of the terminology used in the framework and analysis of its application, as we do here.

In doing this, we make two key academic contributions to the growing interdisciplinary literature on greenwashing. First, we empirically evaluate a framework to assess greenwashing for the first time. Although this framework has already been widely used and cited since it emerged, it was neither empirically based nor tested. We draw on emerging activist research (Gray 2023) and engaged scholarship techniques (Van de Ven 2007) across six in-depth case studies, as well as a survey of policy developments to do so. Second, we build on our empirical findings to propose a revision to the greenwashing assessment framework (see Appendix 1). This is the first revision that is based on empirical data and real-world cases. The revision of the framework responds to needs for deeper understanding of greenwashing as tactics change and it moves into a new “dynamic” stage termed Greenwashing 3.0 (Montgomery et al. 2023:3). Importantly, the revised version of the greenwashing assessment framework also includes diagnostic questions, definitions, and examples to bridge organizational practices with individual green claims, a challenge identified by other researchers (Jones 2019).

The revision and testing of the greenwashing assessment framework is timely as greenwashing is increasingly a topic of great urgency at all levels (product, organizational, and societal), making it essential to understand and monitor. In particular, as the European Union and countries such as Canada, Australia, and others begin creating legal definitions of greenwashing, initiatives that enable independent assessment of these practices serve an important role by reinforcing shared and accepted understandings of the phenomenon that transcend legal jurisdiction. The revised framework overlaps in some respects with the definitions of greenwashing used in regulatory processes, such as identifying misleading omissions in advertisements. The greenwashing assessment framework, however, also seeks to offer guidance for regulators by identifying, defining, and providing new tools to diagnose as yet unregulated and emerging forms of misleading claims and practices, including those made in certification schemes, political communication, and in organizational claims about the future. In sum, there is an urgent need for an updated framework as policy processes and the public increasingly struggle to keep up with increasingly higher volumes of potentially misleading environmental communication.

Therefore, the aim of this research is to update the framework in response and ensure its usefulness in a constantly evolving communications context. This includes identifying gaps and issues not addressed by the original framework or cases where earlier definitions used in the framework did not sufficiently fit to identified cases of greenwashing that have emerged since its publication. Our research also seeks to understand practical elements of the framework’s use, such as the time it took practitioners to assess cases, the language used in its indicator questions, and consideration of how professionals and the broader public could apply the framework. Finally, the update compares the themes and diagnostic questions used in the framework with emerging academic research and definitions of greenwashing and misleading green claims included in new and existing policy. This update of earlier definitions and diagnostic questions has enabled the creation of an assessment framework that best captures all known definitions and applications of greenwashing to date.

The greenwashing assessment framework: structure and use

Appendix 1 contains the updated greenwashing assessment framework. We present it across 12 overarching themes of greenwashing (column 1). The second column provides diagnostic questions associated with the different types of greenwashing, with the aim of helping users assess a claim or statement. The third column contains notes to accommodate relevant descriptions and definitions, citations, and examples that provide further context to the indicators and the diagnostic questions. The fourth column links answers to the diagnostic questions with the likelihood that the statement or claim presents a misleading assertion about environmental performance. The fifth column provides examples, mostly taken from litigation cases, to increase user understanding of each theme.

We structured all questions so that the answer “yes” is associated with a higher likelihood of greenwashing and “no” points to lower likelihood. The framework does not provide an assessment of “better” or “worse” forms of greenwashing of individual claims. The person or organization reviewing a claim must ultimately formulate their own evaluation across types of greenwashing statements or levels of severity. To ease accessibility and use of the framework, we have also included the updated greenwashing assessment framework in an interactive online tool hosted by CSSN at: https://cssn.org/special-projects/greenwashing-tool/.

METHODS

Gray (2023) identifies activist research as studies that respond to serious real-world problems, involves “active experimentation” in collaboration with interested stakeholders, respects the participants’ differing power and agency, and seeks to generate positive benefits over time. It shares knowledge between researchers and stakeholders, thus building the capacity of both. Academic research and professional practice operate on different timeframes and tend to value separate objectives, i.e., peer-reviewed rigor for academics and practical relevance for practitioners (Sharma and Bansal 2020). However, engaged scholarship contextualizes academic research “in relation to shared social problems, public benefit, and a democratic public sphere” (Khoo 2013:22). While engaged research is often associated with teaching and learning within university classrooms, it can encompass a range of practices, including interdisciplinary work and public scholarship, what Boyer called the “scholarship of integration” (1996:26; also see Van de Ven 2007). Our research here is an important part of this trend in scholarship and is informed by, and to some degree co-created with, multiple practitioners, including activists, policy makers, and civil servants, along with researchers examining greenwashing. Thus, as Franklin (2022) would note, it is both creative and collaborative.

The goal of revisiting the original greenwashing assessment framework was to empirically test it against practical applications and developments in identifying greenwashing, rather than to develop new applications through novel empirical analysis. Because the framework had been in active use for two years, we sought to re-evaluate each of the original themes in the framework with respect to developments in greenwashing scholarship, research, and practice, adding practical questions regarding clarity and use. To perform this revision, we incorporated a mixed methods approach that combined consultation with six informed experts using case studies with interviews and analysis of developments in policy and regulation. We sought an array of experts with varied backgrounds in environmental sciences, campaigning, and/or scientific research to conduct case study assessments of the framework. The experts represented varied jurisdictions witnessing changes and updates to greenwashing regulation since our prior study (e.g., Canada, EU, UK). Table 1 outlines these cases.

Because our informed experts were active in a variety of fields, we asked them to propose cases, based on their professional knowledge and activities that they believed needed to be analyzed for greenwash concerns, but for which they did not have a predetermined conclusion nor was there an existing legal judgment. The cases were active and represented a broad spectrum of industries and organizations, highlighting emerging patterns in greenwashing. Many of the chosen cases were particularly illustrative because of their prominence in public discourse, such as high-profile claims of net-zero and neutrality that have attracted attention from stakeholders, media, and regulators. Some cases were noteworthy for their potential to challenge or expand existing greenwash regulations, while others were notable for revealing new forms of deceptive environmental claims not widely recognized before. The experts identified these cases with input from the authors to ensure diversity across sectors. In doing so, we intentionally sought variation across type of organization (both for-profit and not-for-profit), location and regulatory boundaries, size, and stakeholder audiences (shareholders vs. community, etc.) to test the boundaries of the framework. The experts conducted their own case studies using the framework in the spring and summer of 2023. Given the importance and focus on greenwashing in climate related claims, several case studies investigated net-zero and neutrality claims. In consultation with the authors, our participants chose the following six organizations and claims:

1. Panasonic’s Green Impact claims on their website (Panasonic 2024) referring to reducing CO₂ emissions and “achieving net zero CO₂ emissions.”
2. The Global Salmon Initiative’s 2020 report contains claims and reference to seafood being “sustainable,” “eco-friendly,” “responsibly managed,” and “climate-friendly.”
3. Austrian Airlines’ claim to fly carbon neutral, which was originally published on their website. The link is no longer active following a court decision concluding the claim was indeed greenwashing (Memon 2023).
4. Netflix’s net-zero greenhouse gas emissions commitment to be achieved by 2022, published on their website (Steward 2021).
5. Nestlé’s claims on regenerative agriculture published in Nestlé Agriculture Framework (2022) describing its “corporate vision for agriculture as a central building block for a regenerative food system.”
6. Western University’s responsible investing annual report [date unknown], which focuses on “Western’s climate change ambitions and the need for long-term, sustained, decarbonization” of their investments.

Of the six organizations examined, the majority are large corporations (from the fields of electronics, aviation, entertainment, and agriculture), one is an initiative established by over a dozen salmon producing companies, and one is a public university in Canada. The primary objective of the testing was to ensure that the framework could be used to identify greenwashing within these cases, to examine the clarity and usefulness of the wording of the indicator questions for non-academic audiences, and to identify shortcomings within the framework. After completing the case studies, the research team interviewed five of the experts (the sixth was unavailable) about their experiences using the framework. Interviews were in-depth and qualitative, lasting one hour or more and utilized a combination of set and open-ended questions. Interview participants were recorded and also provided a written report for additional analysis.

In addition, to assess how well the original framework met the evolving needs, expectations, and experiences of those engaged in addressing greenwashing, the research team also conducted a review of applications of greenwashing definitions and policies by professional bodies. In particular, we examined the creation of “green claims” policies in the United Kingdom and Europe and the application of greenwashing definitions by the Advertising Standards Authority in the UK, where the Green Claims Code came into effect in 2021 (Competition and Markets Authority 2021). The research team also reviewed dozens of cases from legal and regulatory authorities in the EU and 11 countries, including Austria, Canada, Denmark, France, Germany, Ireland, Italy, the Netherlands, Sweden, the United Kingdom, and the United States. This review provided an opportunity to confirm that the greenwashing assessment framework reflected all the greenwashing definitions active in these bodies, processes, and forums. This review also enabled a comparison of the indicator questions and evaluations from the original framework to how practitioners understand them in policy spaces. In addition, comparing the framework with these policy processes enabled the research team to identify where definitions in the framework go beyond those applied in legal and regulatory spaces.

The authors collectively reviewed and analyzed the findings from these exercises and proposed amendments and revisions to greenwashing assessment framework based on these findings. We summarize our findings and the amendments below.

RESULTS

Case studies and interviews

The informed experts assessed their respective cases using the framework and all found it to be a valuable tool for analyzing greenwashing. At the same time, however, they overwhelmingly identified user-friendliness as a challenge, noting its complexity, “clunkiness,” and difficulty in navigating the spreadsheet format. The experts also responded directly to individual indicators. Comments included specific suggestions on wording changes, as well as more general critiques, such as identifying individual indicator questions as “hard to assess” or suggesting that certain questions presented a “rabbit hole” that would make assessing the claim more difficult. Several experts noted their hope that regulatory authorities would adopt the framework.

The experts also noted that the framework did not clearly address production, visuals, and spending on promotional campaigns. In several instances, they suggested new indicators to address issues arising in their cases. These suggestions included identifying the use of aggregated data to give the impression of positive environmental performance and the inclusion of spokespeople statements as part of an indicator renamed “inconsistent organizational practice.” Such responses informed a comprehensive revision of the indicators, including merging some to improve clarity, changing the wording of most indicators, and adding new indicator questions.

Existing policy initiatives

At the time of the initial publication of the framework, the identified greenwashing policies included the U.S. Federal Trade Commission Green Guides (2012) and the EU Unfair Commercial Practices Directive and Advertising Standards requirements for responsible advertisement in the UK. Since then, the UK Green Claims Code (September 2021) was enacted, while the 2024 amendment of the EU Unfair Commercial Practices Directive, “Empowering consumers for the green transition,” includes provisions for green claims. Although the claims prescribed by these policies largely align with indicators captured in the original framework, specific differences existed that needed inclusion in a revised framework. For instance, both the EU and UK policies address the durability of products, which neither version of the framework explicitly names. However, the framework category on Selective Disclosure, including the lifecycle of products (I.1) accounts for the durability claims in these policies. The EU directive explicitly prohibits “claims based on emissions offsetting schemes that a product has neutral, reduced or positive impact on the environment.” We address offsetting in the Selective Disclosure theme (I.3). Our revision of the greenwashing assessment framework has also broadened the indicator to capture claims on climate neutrality that rely on offsetting and also addresses net-zero claims in the “Vagueness” indicator (X.3).

Legal decisions over green claims

There has been a surge in climate litigation “from a mere handful in 2017 to over 140 globally at present” marking a “critical shift in the battle against climate misinformation” (Setzer and Higham 2024:37). More than half of those cases have reached official decisions and about 70% of those concluded in favor of the claimant. Among these, “climate-washing cases” (40) typically centered on claims around the climate neutrality of particular products and services. Our research reviewed 57 cases from legal and regulatory authorities in a dozen countries (Appendix 2). Many of the cases refer to multiple greenwashing themes and issues. The majority of cases focus on two principal greenwashing categories: inadequate substantiation and unclear, unfounded, or false climate related claims. The next most common issues were: not living up to an absolute claim; omission of significant information; claims using vague and ambiguous language; and those that exaggerate environmental benefits. Fewer cases address greenwashing categories like using fuzzy metrics; addressing a fraction of main business activity; referring to a portion of a product, dubious certifications, and referring to actions required by law. The revised greenwashing assessment framework covers all these greenwashing themes and issues. Some applications of green claims legislation included the use of proportionality as a measure of the credibility of an environmental claim, an issue not addressed in the original framework. Along with comments from the case studies, a review of these claims supported revisions to the wording of themes: Just Not Credible (V) and Misleading Symbols (XII) theme, now renamed Misleading Imagery (XI).

There was notable consistency across the case studies, interviews, and published literature regarding the need for a rigorous, comprehensive, peer-reviewed framework for assessing greenwashing that could be applied to real-world examples. From the case studies, one of the most frequently received comments was the need to make it more accessible and user-friendly by improving the wording and presentation of the indicators. Simplifying and refining wording and merging indicator questions thus became a critical objective for this revision, building on the evidence from emerging case studies and policy developments.

Updating individual greenwashing themes

In the revised framework, some themes and indicator questions remain unchanged (e.g., Jargon, theme XII) whereas others have undergone significant revision. To make the framework more accessible and simpler to use, we have merged two themes (“Lies” and “No Proof” under the new title “Falsehoods”); merged indicators (e.g., under “Selective Disclosure” and “Empty Claims”); reduced the number of indicator questions, and shortened or clarified the phrasing of most questions. This section summarizes the definitions of each theme and its diagnostic questions. In addition, the “Notes” and “Examples” columns of the framework present more detailed discussion of the themes, indicators, and examples.

Selective disclosure

This theme includes all kinds of partial, incomplete, and insufficiently contextualized statements that can mislead the public. Selective disclosure emphasizes “positive information about a company’s environmental or social performance, while withholding negative information on these dimensions” (Lyon and Maxwell 2011:5). This is one of the most well-established forms of greenwashing with extensive empirical and theoretical foundations in the research literature (European Commission 2021). A typical example of selective disclosure are claims of net-zero or climate neutrality that omit key details or more negative aspects of a firm’s operations. For instance, the UK’s Advertising Standards Authority (ASA 2023a) found that an ad by Repsol SA was misleading regarding information about how and when they would achieve net-zero emissions. Another example is that of the Pathway Alliance, an association of Canadian oil sands producers, which failed to disclose total annual GHG emissions as well as scope 3 emissions when communicating about its net-zero ambitions (Aroncyzk et al. 2024). We retain this theme from the previous version of the greenwashing assessment framework, but substantially revise indicator questions to eliminate confusion around the differences between indicators I.1 and I.3, simplify wording, and address recent changes in the policy context of off-setting and neutrality claims. As a result, our proposed revision includes 3 diagnostic questions for evaluating selective disclosure: disclosure of all relevant information, provision of adequate information when making comparisons, and reduction of environmental harm before making offsetting or neutrality claims.

Empty claims

This theme includes exaggerations of environmental benefits as well as failure to allocate adequate funding to a green initiative relative to its marketing budget. Organizations can exaggerate the impact of their green practices by overstating their goals or commitments that (a) have not been fulfilled; (b) are unlikely to be achieved based on available information; or (c) do not lead to any follow-up action with measurable and significant impact. Setting dates far into the future without producing regularly updated interim goals also falls under this theme, and has even been studied as a new mechanism termed “future-washing” (Montgomery et al. 2023). An example from the aviation industry includes advertisements featuring the claim “we are taking a louder, bolder approach to sustainable aviation” by Etihad Airways (ASA 2023b). The UK’s ASA ruled that there were currently no initiatives in operation within the aviation industry that would adequately substantiate such an absolute green claim like “sustainable aviation.” Oil companies have promoted the production of biofuels from algae as a promising technology to decarbonize the transport sector for years, even though they have failed to provide adequate research funding, and commercial viability was always in doubt (Westervelt 2023, Arnold et al. 2024). We have substantially revised this theme by merging the previous indicator questions II.1 and II.3 and simplifying them to create a single indicator for assessing exaggerations. We kept Indicator II.2, though we simplified the wording.

Irrelevant

This theme addresses cases where organizations present information that is irrelevant to its environmental claims. This is especially concerning when claims, certifications, and labels separate means (metrics and reporting required by a certification, for example) and ends (actual environmental impact). Research on Leadership in Energy and Environmental Design (LEED) standards, for example, has shown that firms are able to gain certification without actually achieving the goal of the program, which is reduced remissions (Flowers et al. 2020). Liute and De Giacomo (2022) also find that firms certified as B Corporations can underperform or fail to contribute to environmental reduction goals, and research on ISO 14001 standards have similar findings (Garrido et al. 2020). Another example is a case investigated by the UK’s ASA into recycling claims by ELFBAR e-cigarettes in its advertising. Existing legislation (The Waste Electrical and Electronic Equipment Regulations) requires producers to finance the return of vapes for recycling so the court held that consumers could misinterpret the recycling benefit of the product (ASA 2023c). The experts in our analysis identified challenges with the wording of this indicator and, in the case of a university fossil fuel divestment campaign, a difference between irrelevance based on legal requirements versus discussing environmental issues with no bearing on the issue of interest. This distinction is reflected in the revised framework.

Lies, no proof, and falsehoods

Concern about “Lies” is a common theme in conceptualizations of greenwashing from advocacy groups such as UL Solutions’ (2009) “Sins of greenwashing.” A prominent example is ExxonMobil’s public denial of global warming despite studies by its own scientists showing the negative impacts of burning fossil fuels (Supran et al. 2023). The Dutch Advertising Authority found that Colgate-Palmolive misled consumers with claims that the Ajax cleaner bottle was “100% recyclable” and made of “100% recycled plastic,” because the company was unable to prove these claims (Dutch Advertising Authority 2024). However, differences between terms such as lack of proof, lies, and use of disproven metrics are not always so clear. Each of these practices is potentially deceptive and concerned with how claims are supported, but there are also differences between an organization knowingly making a false claim versus making a claim without providing adequate evidence. The updated framework retained the questions associated with “lies” and “no proof,” but merged them within a new theme, “Falsehoods,” because both address inadequate substantiation. Although scientific consensus is not a perfect metric, as one informed expert noted, the framework considers that lacking scientific consensus on an issue or lacking robust, independent, verifiable, and generally recognized evidence for a green claim is enough to arouse suspicion. Lies often result from manipulating baseline calculations, or by choosing convenient variables, as several of past litigation cases have shown (e.g., ASA 2022a, 2022b, Sabin Center for Climate Change Law 2023). Ignoring scientific data or findings has therefore become a strategy for hiding negative environmental impacts (Franta 2021). Therefore, we moved the indicator on false/inadequate methods from the Vagueness theme to “Falsehoods” because it better fits a theme concerned with the accuracy of information.

Just not credible

This theme includes both claims that suggest demonstrably harmful activities are environmentally friendly and claims that are disproportionately small compared to the size of the problem they allegedly address. For example, in June 2023 the UK’s ASA found that ads by Shell were likely misleading because they gave the impression that a significant proportion of their business was lower-carbon energy products without providing information on the relative proportion of lower- and higher-carbon products in their business model (ASA 2023d). A Dutch court ruled in 2024 that KLM misled consumers by suggesting the company’s operations could be sustainable using forest-based carbon credits and so-called sustainable aviation fuels, emphasizing that these measures only marginally reduced aviation’s negative environmental impacts (Amsterdam District Court 2024). In the new framework we add an indicator addressing the proportionality of green claims. These revisions address specific challenges raised by users of the framework examining claims within industries known for having a negative impact, such as oil and gas or fast fashion, as well as the proportionality test applied in green claims legislation.

Inconsistent organizational practice

This theme revises what previously was “corporate social responsibility in action” and expands it to include public statements and firm-wide actions, as well as legal and proper use of certification schemes pertaining to environmental claims. We moved this indicator here from the “Dubious certifications” theme to reflect that organizational practices more accurately address the need to conduct due diligence of third-party certification. For example, research has examined firms’ attempts to greenwash using complex firm-supplier relationships in global supply chains that limit stakeholders’ ability to identify and place responsibility for environmental misconduct (Pizzetti et al. 2021, Comyns et al. 2022). Research has also emphasized the contradiction between fossil fuel companies’ green rhetoric and their actual business practices (Li et al. 2022, Trencher et al. 2023, Gentile and Gupta 2025). Furthermore, IKEA’s sale of what they claimed to be FSC-certified timber products, actually came from wood illegally harvested in Ukraine’s old growth forests (Earthsight 2020). None of the issues covered by these two indicators are required by law, but can include practices with significant environmental impacts.

Dubious certifications and labels

All the usual considerations of making credible green claims apply to certifications, but certification schemes and labels also present unique greenwashing challenges (European Commission 2021). Certifications and labels identify various products or organizations as better for the environment with external experts validating the use of good environmental practices in the organizations or what they produce (Harrison and Moffat 2014). However, this practice can also be misleading, often by offering a weak or less stringent certification to compete with a prior, recognized, certification (Delmas and Burbano 2011, Lyon and Montgomery 2015). Such competing labels are frequently industry-backed, rather than led by independent organizations thus allowing producers to choose from an array of practices to achieve certification. This limits commensurability and increases obfuscation and consumer uncertainty with research noting, for example, that label proliferation has created a state of “aggregate confusion” (Berg et al. 2022:1350). Labels thus claim environmental credentials without actual measurable change in harmful practices. An investigation by several NGOs showed that the Aquaculture Stewardship Council (ASC) weakened its standards to the point that there was little improvement in environmental practice by those who touted the label (SeaChoice 2018). Our updated framework substantially revises this theme in response to informed expert comments and challenges regarding how realistic ease of access requirements are.

Political spin

This theme addresses issues of lobbying and other political activity alongside affiliation with think tanks and other organizations that contradict green claims. This indicator remains unchanged from the previous framework. Critical studies of environmental sustainability initiatives reveal the need to evaluate the influence that industry or other groups have on environmental claims-making (Brulle 2014, Lyon et al. 2018). Lobbying activities can be difficult to assess, but are traceable through examining lists of registered lobbyists, where available. For example, organizations, such as the Center for Responsive Politics (OpenSecrets) and InfluenceMap, have developed robust data on lobbying activity, campaign finance, and other political activities. An example here is the European aviation industry, which, despite claiming to support net-zero carbon goals, actively lobbied to oppose key domestic and EU aviation policies on climate, including making aviation fully part of the EU Emissions Trading System, kerosene fuel taxes, and ticket taxes on flights (InfluenceMap 2021).

Co-opted endorsement

This theme addresses relationships between organizations in which one organization enables or supports another organization’s misleading environmental claims. Examples include British Cycling’s endorsement of Shell’s net-zero claims (Dubbins 2022) and partnerships between the World Wildlife Fund and organizations such as Shell, Monsanto, and HSBC that benefited from the group’s green image while carrying out harmful environmental practices (Vidal 2014).The updated framework has merged the indicator questions within this theme to reflect that endorsement of greenwashing claims is the same as making greenwashing claims, regardless of whether doing so for payment. As with others noted above, this indicator addresses greenwashing issues beyond what the law requires.

Vagueness

This theme addresses claims that are so general that they are misleading. Specifically, it speaks to inadequately defining the scope of a claim, using ambiguous language, or failing to follow relevant guidelines when making claims as with net-zero, for example. Vagueness is a common form of greenwashing and examples include the use of terms such as ethically sourced, green, natural, or sustainable without clarification (European Commission 2021). Linguistics research shows that greenwashing may use specific forms of simpler and more complex language to decouple or cloud their actions and words (Crilly et al. 2016, Fabrizio and Kim 2019). A recent example among many is the claim “Good for the planet” by plant-based beverage and yogurt producer Alpro (UK) Ltd., which the ASA ruled as misleading (ASA 2021). We merged the previous fourth indicator question, about metrics, with the second indicator to make a single question requiring that green claims adequately define the meanings and definitions behind them. Vagueness is being regulated in several jurisdictions. For example, the EU’s recently amended Unfair Commercial Practices Directive bans the use of generic environmental claims like “environmentally friendly,” “natural,” “biodegradable,” “climate neutral,” or “eco” unless these claims can be proven (European Parliament 2024).

Misleading imagery

The wording and presentation (i.e., layout, choice of colors, images, sounds, symbols, or labels) of a claim has to be a truthful and accurate representation of the environmental benefit. Although organizations are free to use environmental imagery, the practice can be misleading if it implies that the environmental aspect of products or behavior are more significant than they actually are or redirects attention away from environmentally damaging organizational activities (European Commission 2021). Nature-evoking imagery can mislead consumers regardless of their knowledge about the subject (Parguel et al. 2015). It is important to note that cultural context matters regarding understanding and interpreting imagery and should be a consideration in conclusions around greenwashing. We revised this theme to reflect how imagery is evaluated in green claims policy, as well as in empirical research on social media. For instance, Supran and Hickey (2022) identify disproportionate use of environmental imagery in their analysis of social media communication by fossil fuel, aviation, and car manufacturing companies, with nearly half of their posts featuring “green innovation” separate from the core purposes of the companies and the environmental harms that come from them. Similarly, research revealed that after the Deepwater Horizon disaster, BP avoided environmental claims but instead used imagery presenting itself as scientific, professional, and responsible (Kassinis and Panayiotou 2018).

Jargon

Jargon is the use of complex and technical language that obstructs understanding. Research points to the frequent use of complex language in greenwashing to shroud claims, revealed by Fabrizio and Kim (2019) through computational linguistics with a “fog index.” Our informed experts and their case studies further affirm this frequent practice. Access to and understanding of information about the environmental performance of products or organizations can reveal a significant imbalance between advertisers and consumers, making it difficult to verify environmental claims (Kaupa 2021). Consider the use of jargon to greenwash technical terms that disguise likely pollution from plastic products, for example, where terms such as “oxo-degradable” obscure the fact that these products contain petroleum and will break down into harmful microplastics (Ellen MacArthur Foundation 2021). We did not revise this indicator for this revision of the greenwashing assessment framework.

DISCUSSION

Beyond legal definitions of greenwashing

We examined several dozen litigation cases (Appendix 2) and found that the updated framework addresses all greenwashing issues raised in front of courts, advertising authorities, and competition bureaus. Revising the greenwashing assessment framework has resulted in a better overview of the themes and issues appearing most frequently in litigation cases as well as others less examined. The themes “selective disclosure,” “empty claims,” “falsehoods,” and “vagueness” still dominate greenwashing regulation, while the legal cases reviewed rarely addressed themes such as “dubious certifications and labels,” “irrelevant” claims, and “political spin.” We intend this framework to address greenwashing in all known forms, not only those required by law and policy. Our empirical findings have demonstrated that the framework’s definitions include and exceed legal standards currently in use to assess greenwashing claims. The following topics included in the framework exceed requirements established in national competition and consumer protection regulations.

Offsetting and net-zero

Debate over offsetting carbon emissions and other negative environmental effects has expanded substantially since the publication of the original greenwashing assessment framework. Making climate neutral or net- zero claims has become more complicated from a legal perspective throughout the world. For instance, the UK’s ASA has tightened rules on the use of terms such as carbon neutral and net-zero (for an in-depth discussion see Kaupa 2022). The new EU Green Claims Directive will go even further, requiring recognition from approved certification schemes for claims about offsetting schemes for residual emissions. These legal regimes are complemented by watchdog groups, such as the New Climate Institute, whose “Corporate Climate Responsibility Monitor” provides in-depth evaluation of corporate net-zero commitments (NewClimate Institute 2024). The term “residual emission” is too often used to wrongly justify offsetting because there is not yet a robust definition of what reasonably constitutes actual residual emissions. Offsets are most likely greenwashing when organizations use them as an alternative to emission reduction. Offsets hidden in net-zero or neutrality claims without transparent communication about the extent and nature of the offsetting are clear cases of greenwash in light of the consistent findings that offsetting schemes overstate their benefits (Haya et al. 2023). Offsetting claims can mislead people into thinking that decarbonization is actually happening when it is not (Anderson 2012, Kaupa 2022, Trencher et al. 2023). Conversely, the greenwashing assessment framework does not consider contributions to projects that aim to store carbon long-term as greenwashing, so long as those contributions are not claimed to have neutralized the organization’s environmental impacts.

Greenwashing and obstruction

Climate obstruction has become an important, complex, and emerging area of research that addresses some of the same behaviors as greenwashing. Dunlap and Brulle (2020) draw attention to the well-organized and financed networks of corporations and other actors who actively seek to obstruct meaningful climate policy. Studies of obstructionist tactics highlight a shift from outright denial (i.e., literal denial of climate science) to a more recent focus on creating doubt about proposed climate solutions via discourses of delay (Lamb et al. 2020) and misperceptions about climate responses (Coan et al. 2021). For example, Lamb et al. (2020) identified 12 climate delay discourses that accept the existence of climate change but emphasize inaction or inadequate efforts. These contrarian arguments also focus on the negative social effects of climate policy, raise doubt that climate mitigation is possible, and claim that climate policies will harm the economy. Overall, climate obstruction activities include mainstream and social media campaigns, lobbying, funding politicians and political campaigns, and disseminating climate-delaying discourses and practices (Lamb et al. 2020). Although there are some instances where obstructionist groups employ greenwashing, e.g., the now-notorious Exxon campaign around algae biofuels (Supran and Oreskes 2017, Li et al. 2022), it is important to distinguish between intentional and malicious deception and mistakes, oversights, and poor practice in communicating good environmental actions. The purpose of the greenwashing assessment framework is to improve understanding and definition of how environmental communication can mislead and to foster sound environmental communication.

CONCLUSION

In this article, we proposed an updated Integrated Framework to Assess Greenwashing (Appendix 1) that reflects the new and evolving understanding of greenwashing and its assessment. This updated framework draws from empirical research co-created with insights from informed experts and practitioners in civil society and advocacy groups, academia, and a review of global policy, legal, and regulatory processes. As a result, we have thoroughly updated the greenwashing assessment framework, including comprehensive changes to wording across all indicators, the removal and addition of indicator questions and themes, and revised notes for all indicators. This work is an important contribution to the important need for ongoing conceptual clarification and assessment of the complexity of greenwashing in its many forms.

However, like all frameworks ours has limitations. Although the updates improve its clarity and relevance, the greenwashing assessment framework is not exhaustive and may not fully capture the nuances of every instance of greenwashing, especially in rapidly changing industries or emerging markets. Additionally, the reliance on certain qualitative judgments in the framework’s application can involve subjectivity. As greenwashing continues to evolve, further refinement and development of the framework will be necessary. For example, advancements in machine learning and specialized industry-specific methods (NewClimate Institute 2024; Oppong-Tawiah and Webster 2023) offer more sophisticated tools to identify, track, and assess greenwashing in real-time. Such technologies hold extensive promise for future academic research as well as policy and environmental practices.

Looking ahead, we envision multiple uses for the updated greenwashing assessment framework. For example, it can serve as a practical tool for advocacy groups, policy makers, and academics, guiding future research and regulatory efforts. This application is of particular significance as scientific knowledge comes more frequently under attack by national governments and others. Furthermore, companies themselves could use the framework to screen their communication strategies or those of suppliers and partners, ensuring that their environmental claims align with legitimate sustainability practices throughout their supply chain rather than falling into greenwashing. Finally, there is a need for continued research and monitoring in the face of the “triple planetary crisis” (UNFCCC 2022) of climate change, biodiversity loss, and pollution, underscoring the urgency for robust, transparent, and actionable environmental claims across all sectors of society thus improving the way we communicate about planetary needs.

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