Standards on environmental marketing (“green”) claims are quickly evolving in the US, EU, and UK. Keen to ensure that the voices of impact-focused companies are represented in this evolution, Provenance recently submitted comments to the US Federal Trade Commission as part of their 10-year update of the “Guides for the Use of Environmental Marketing Claims” (the “Green Guides”). This was a unique opportunity to shape the conversation around environmental marketing claims in the US. As part of this submission, Provenance engaged its community in a survey to identify the highest priority sustainability issues facing beauty brands today.
Curious to know what Provenance found as part of this exercise? Read on to see some of our key findings and recommendations submitted to the FTC.
A continuing need for the Green Guides
The retail market is experiencing a shift towards value-driven shopping, with 79% of consumers changing their purchase preferences based on sustainability. However, due to the prevalence of vague terms like “green,” “clean,” or “eco-friendly,” the number of brands accused of greenwashing (i.e., making misleading or unsubstantiated green marketing claims) is on the rise.
While brands often want to develop responsible marketing claims, the standards for how to do so are often unclear. In response to Provenance’s survey, the majority of brands indicated they had a low-to moderate understanding of the current US guidelines on green claims.
In addition, 92% of brands responded that greater clarity or more specific rules around green claims would be helpful to them as a business.
Brand feedback reinforced the need for clear, thorough, and consistent guidelines for environmental marketing claims.
Benefits to an improved Green Guides
Benefits for Consumers
A robust set of Green Guides provides an important consumer protection function for shoppers wishing to purchase sustainable goods and services. According to Provenance’s 2022 Skin Deep Beauty Report, while consumers are more frequently shopping with sustainability in mind, 71% of consumers aren’t sure what ‘environmentally friendly’ means and 62% say the same for so-called 'green' claims. As the complexity of green claims grows, and as additional claims join the marketing lexicon, the Green Guides must also evolve.
Benefits to Brands
There is a significant opportunity for businesses, particularly small businesses, to gain market share given the growing consumer demand for sustainable products. In a survey by Capgemini, 77% of businesses said their sustainability approaches increase customer loyalty and 63% saw a revenue uptick. However, this value can only be captured accurately when there is a level playing field among companies. A robust set of Green Guides would ensure that brands are able to benchmark their green claims against their practices in a fair and transparent manner.
Proposed Modifications to the Green Guides
Robust Guidelines and Clear Examples
During Provenance’s conversations with brands, the most requested feature to the next iteration of the Green Guides was a more robust set of examples that illustrate how to make and substantiate specific environmental marketing claims.
In particular, nearly 80% of brands that participated in Provenance’s survey felt that they needed clearer guidelines around the term “sustainable.”
Equally beneficial would be the inclusion of guidance on how not to make certain claims so that brands have clear parameters on how to avoid greenwashing.
A number of brands also referenced the concern around greenwashing as resulting in a new phenomenon: greenhushing. They felt that the vague parameters around how to appropriately make environmental marketing claims for their products led to a hesitation to speak to these practices at all. In the interest of creating a market where consumers have access to the most comprehensive information around brands’ sustainability practices, clear parameters on discussing these practices should be a high priority for the FTC when updating the Green Guides.
Recognizing New Technologies
Marketers often struggle to provide meaningful information to consumers about the environmental credentials of their products or services. New technology solutions that have developed since the last iteration of the Green Guides, such as Provenance, provide a scalable solution to this problem.
As one brand that Provenance spoke to flagged, “[t]he concepts and systems that we’re working on have changed or evolved significantly in recent years, with new terminology, technology, and understanding of the climate crisis”.
For example, Provenance’s Proof Points are clickable sustainability claims about a brand or a product. Using technology, they connect what brands say (e.g. Organic Ingredients, Widely Recyclable Packaging or Renewable Energy) to real evidence or independent verification.
Brands are recognizing that these new technology tools are becoming available, and are expecting the Green Guides to adapt alongside them.
Harmonizing with EU and UK Standards
Because so many brands are exploring markets in multiple jurisdictions, a number of brands requested that the FTC consider emerging standards within the EU and the UK when developing new US guidelines. This would allow brands selling across markets to ensure that their green claims follow clear and consistent guidelines, thereby reducing the burden on business. For additional context, see Provenance’s recent thought leadership on the UK Advertising Standards Authority guidance on “carbon neutral” and “net zero” claims and European Commission consumer protection proposals targeting greenwashing and sustainable purchasing.
Third Party Certifications and External Standards
During Provenance’s discussions with brands, over 70% of brands reported that they relied on external certifications - including product lifecycle assessments - to substantiate their green claims. Brands should be encouraged to leverage the trust conveyed with external certifications when making sustainability claims, and clear guidelines around how to do this would facilitate a wider adoption.
Provenance facilitates a brand’s ability to communicate claims tied to third party certifications and external standards via the Provenance Framework, an open-source rulebook of 125+ social and environmental impact claims and certifications. Each claim comes with clear criteria for what constitutes legitimate evidence, as well as guidance on how to communicate it publicly. This gives users clear, robust parameters for what they can and can’t legitimately say about its brand or product(s).
Bringing it all together
If one thing was made clear during Provenance’s discussions with brands, it is that industry collaboration and transparency are a necessary component of these new Green Guides.
A huge thank you to all the brands that engaged with Provenance as part of this process, providing valuable insights and suggestions.
If you’d like to read Provenance’s full submission to the FTC, you can find it here. And if you’re interested in aligning your sustainability claims with available standards and certifications, check out the Provenance Framework here.