Free panel discussion

Greenwashing is a problem that concerns any of us.

Quoting someone else, we can say: “Greenwashing is a beast, is huge, it’s pervasive, and everyone is in it”.

It doesn’t mean that people are evil, but there is very low awareness of this topic, and this is the reason why, at The ID Factory, we’ve decided to organize a panel discussion called “How to fight greenwashing”.

During the panel, we had amazing speakers: 

• Silvia Mazzanti, Sustainability Manager at Save the Duck
• Alice Siracusano, CEO at LUZ Agency
• Veronica Muratori, Associate at Withers Worldwide.

The panel was moderated by Martina Schiuma, Head of Sustainability at The ID Factory.

How do you avoid greenwashing and how do you communicate this commitment?

M: “Starting from what is greenwashing, I’d like to stress one aspect. Saying something false is not the only reason for greenwashing. Also, vagueness information about the product, avoid saying all the necessary information, false information, or not proven information that would still be greenwashing.

Even very catchy marketing slogans may be accused of greenwashing because they do not explain or provide the information to verify that they are trustful commitment and statements and claims about greenwashing.

That’s an important topic to take into consideration when speaking about the best practices to avoid greenwashing and I will start with the first question for our speakers which is: “How do you avoid greenwashing and how do you communicate this commitment?”

S: “Well, talking about being boring I am considered the boring one in my office because I’m always telling that it is something that is not going on in the right way about campaigns and ideas that creatives are proposing or the Style Office.

When they propose ideas, fabrics, and an innovative mix of materials, I’m always the one who’s saying “No”, but it’s not just because we don’t want to be innovative, of course, but because by not considering the echo design principles very often, you are obliged to avoid or hide information to stakeholders.

So everything is linked together: it starts from the beginning from the study and development of the project or garment specifically and it has to be fulfilled for the whole value chain.

This means that also the communication campaigns have to be consistent with what has been done in upstream phases and well usually what we do is collect a lot of data because we are a Benefit Company and B Corp. 

We have to report, we are engaged also with UN global conflict, and we have to report about our impacts and that means that everything that is inside the report has to be proven and has to be solid.

This is not very easy and if we do a hard job on that side, on the other side the creative people from the marketing department have bizarre ideas that are not matching what we are, our task, and our goal, well usually I’m the one who’s opposing.

It happened already that we had to stop campaigns because there were some critical topics and that was not a nice experience but luckily we had no other consequences about that.

It’s very important to pass straight messages, as complete as possible, and trustful and clear to stakeholders, so we do it through our reports and our website, where we have an official place where to communicate sustainability topics, but also on social tools we have dedicated campaigns, and that has to mesh together with a fashion one that it’s not very easy sometimes.”

A: “Actually I’m the guy who helped corporations, such as Silvia’s one, to figure out if the message that they are going to convey is verifiable. 

So it is based on remarketing indeed; so our suggestion is to rely on facts instead of on claims. That is particular from an advertising agency to listening to this kind of message but we do believe in it because, as a big core content marketing agency, we value integrity. So we work only for companies that want to convey sustainable messages backed with concrete evidence. 

And a good proxy of a client’s level of sustainable conduct is the reaction toward our initial conversations because before starting a partnership, we share our ethical code and we also specify the depth of the relationship that we would like to create with our clients. 

Before starting a partnership, we start with the internal interviews with the top management and the employees to understand how much the practices that they want to communicate are actually in place and working. So you may understand that their reaction reveals how much they are concretely involved in sustainable practices.

I don’t want to anticipate an aspect that may be touched by Veronica, but it is also important from a legal point of view because being an advertising agency if the advertising product for a corporation based on green marketing is wrong or objectively unverifiable, the advertising agency may also be held liable.”

V: “Yes, correct! You should have a strong agreement with your agency, that’s my suggestion if you are, you know, a brand.

Coming to Martina’s question, you know from a legal perspective first thing first, to me, to avoid greenwashing is to know what greenwashing is. 

So from a legal standpoint again greenwashing refers to green claims, environmental claims, that are not true or cannot be verified.

Those claims usually create the impression that:

• a product or a service has a positive impact on the environment
• has no impact at all
• is less damaging to the environment than, for example, a previous version of the same good or services compared to a competing goods or services

The thing is that all aspects of a claim might be relevant in terms of greenwashing, so you should keep in mind that when you are choosing the meaning of the specific terms, the meaning of such terms is relevant or the evidence you have for confirming such claims are very important. 

Even the colors, the pictures, logos, or whatever you are using, you also should consider the overall presentation of the claim, because the law refers to the idea, again, that the claim can be implicit or explicit. So all those aspects are very important when you are talking about a specific claim and deciding what claim you want to create and use in the future.

The overall product presentation must be crucial in terms of green claims from a legal standpoint.

The law requires that green claims shall be truthful, not contain forced information, shall be presented in a clear, specific, accurate, and unambiguous manner, and the final goal is not to mislead the consumers, or the public.

Your claim shall not deceive the other or again shall not be likely to deceive the average consumer.

Even if the information is factually correct, it should not in any case deceive the consumer. 

What the legal guidelines and what the case law refers to – and your lawyer also will say to you – is to keep attention to the use of generic claims, for example, “ecological environmental correct”, “climate-friendly”, there are many examples of very generic claims. You can use that kind of claim, but if you decide to go that way, it’s harder, because you need to have sufficient detailed, proven evidence that the claim is true and cannot be misleading to the public, and this is not so easy.

Another crucial point is to keep your claim, and the data that support your claims, always updated: you should have it at the time you propose your claim and later on. 

Another important aspect to consider is to look at the overall life cycle of a product. An environmental claim should relate to significant aspects, in terms of the overall product impact, not only a part of it, and this is quite important when you choose the claim.

Another important fact is where you decide to use such a claim because sometimes you need to provide more information, and if you want to provide more information, for example, if you are putting your claim in packaging or whatever where there is limited space for specification, sometimes you shall provide something more, in order not to mislead the public, not to mislead the consumer. 

You should think about all those aspects when you are planning and considering your advertising.

In the end, the idea is that sometimes, for example, it’s better to say “lower-impact” than a straight claim like “ecological”: all those claims, less vogue, less generic, are usually better than the straight and the generic one.”

How do you communicate the structured data that is behind the product?

M: “Thank you for all your answers.

I noted down the keywords from your answers: Silva was saying “the value chain”, how to prove what’s behind the product, using a straight communication which wants to tell the final user the facts that are behind. 

Alice was mentioning the role of interviews, and getting in contact with the partners because you need to know them. As a communication agency, you cannot say anything, if you don’t know the company behind it. 

From a legal standpoint, the communication needs to be clear, specific, and accurate. So looking not only at the final result, but looking at the entire product and its impact of the product across the entire value chain.

That means that the communication you are making should be consistent, not only with what you are doing as a company but with what all partners along the supply chain are doing as stakeholders.

The (next) question here is about transparency: “how do you communicate the structured data that is behind the product?” I also saw a question which was saying “how do you communicate that to a short attention span customer?”, because actually, the point is also that how do you select this data? 

I want to ask you if you have any relevant case studies you would like to share about your experience, about how you select this data, and how you communicate that.”

S: “The data selection is for sure not an easy job: it’s a long process that starts with the selection of the material topics that you want to relate on, it’s strictly connected to the sustainable action plan that you have in a company – usually we’re talking about responsible companies, so they’re supposed to have a structure behind these initiatives -.

So when you know what’s your business, and what your impact is because you made your risk assessment, you developed your plan to enhance and avoid or reduce your emissions or inevitable negative impacts in general, you focus on specific topics because you made your materiality analysis, involving and selecting your stakeholders, it means for sure your people inside the company, your manufacturers, your agents, customers find clients from wholesale, a channel for instance. 

Certainly, it has been finished and you know where you have to focus your attention, then you can start collecting your data involving old inside departments to collect this data and spread these requests around to all suppliers. 

This means for sure the direct suppliers for the core business, that for instance, we have to produce jackets and garments generally but also to other stakeholders around us: our partners that can be for instance forwarders or the warehouse or the landlord, our building, the headquarters, the shops, etc. It’s a very wide net that we are moving and also the incoming data are very very barriers and difficult to handle. 

So it’s very important to have some kind of boxes to organize everything – The ID Factory created an excellent tool in this sense. – 

At the moment since we are SME – it’s more medium than small now, we’re moving to the next level – we’re focusing on collecting data even though we don’t yet have a system to organize all this data and it’s getting very complicated now.

In the next future, I’m sure we’re going to look for a tool that can help us because when you have your data, you have to organize them and they always have to be available. This is something that final customers and b2b customers are asking a lot of us. 

Every season big players, like Zalando or other international ones, are sending to us specific requests where they want to assess the level of certificates and proofs that we have and they want to receive the real documents. 

So it’s a serious way of approaching the topic and it’s reaching the final user now that it’s directly dealing with us when they want to have a specific answer but they also trust wholesalers. So even wholesalers have to be ready they have to handle this information.

We have to get well-organized data available for any request from the market.”

A: “I would add a new type of stakeholder above all that are clients, that are people connected to this panel because as an advertising agency I would always suggest trying to connect with the final audience.

There’s a lack of specific requirements of specific data to be provided to prove the positive impact that a company has. 

This is a problem because the consumers, the public, cannot understand which data prove a real impact and what data instead do not prove them. 

We can transform this lack of specific requirements into an opportunity by asking consumers what data they would like to see, to enforce their trust in our brand.

I know it is hard because you have to involve a big audience in some cases, but this also serves another important cause, the death of climate deniers, because these people are skeptical by nature and their skepticism is fueled by greenwashing.

The nature of their distrust is not a matter of what is being said, but of how the subject – so the brand – engages with the audience.

We should invite them to take part in the measurement process by suggesting the type of data that has to be provided, to better understand how our company positively impacts the ecosystem and the communities of employees, clients, suppliers, and all the other stakeholders.

My suggestion is to involve the final audience in the measurement process.”

V: “I agree that there is not a clear background on the specific data to be provided but the clear fact is that, from a legal perspective, data are very important because traders must have the evidence to support their claims and they should be ready to provide such evidence to competent enforcement authorities, immediately and understandably. 

You should have a clear report because if the claim is challenged, you should be ready. 

This is something that it’s closely related to what the regulation requires of the traders: any claim, even environmental and green claims, should be based on evidence that can be verified by the relevant competent authorities. 

The burden of proof, regarding the accuracy of the claim, is on the trader or the agency.

In my experience, there is a sort of mismatch in that, because sometimes traders are very keen not to reveal too much of their trade secrets or know-how because sometimes data and reports reflect the process because there is a lot of research and development behind the final results. 

Also, our part is not so easy, because we need to balance on one side what is the legal requirement and, on the other side, what the companies usually prefer and to keep the secret secrets in the end. 

I think that reports, data, and documentation are very important. 

There is a very recent case that, not based in Italy, is a case about the All Birds brand, closely related to the green and sustainable practices. Last week the US district of New York against All Birds on greenwashing because the certain claims of the companies have been challenged, in particular related to sustainable practices, low carbon footprint, and other initiatives of the brand that have been, at first, challenged as full sort of misleading.

It’s a huge case but what I want to mention here is the fact that the company has carried out a specific life cycle assessment, so they have data to prove their green claims, they have measured the environmental impact of materials and whatever. 

They’ve been challenged because the consumer association thought that such claims were not considering all the possible aspects, all the possible methodology and I think that this is related to what Alice was mentioning because you choose a tool, a method. If there is not only one specific way or one law but go straight to the point and you have to comply with it, it’s not so easy. 

In the end, All Birds choose one method, to conduct his life cycle assessment, and provided to the consumer the data based on such life cycle assessment (that was based on technical regulation with a scientific approach, etc.) but in the end, the result is that the claim was not misleading because everything was clear, everything was with scientific proof. 

So even if there are a lot of gray areas, when it comes to green claims the decision suggests that companies have some flexibility in how to measure the environmental impact of the product. 

This flexibility has some limits about what kind of methods you are choosing, should be robust and clear and strong, but in the end, if you choose one way and then go straight to that way, in this case, it’s okay, you’re right, so I think that this is something very important for all of us.”

What are the data customers have to look at to make sure a company is acting sustainably?

M: “I agree, Veronica, and I would like to add something to that because for instance there is a new European law, The Due Diligence law, which will require companies to trace their supply chain and to give evidence about the social and environmental compliance of the suppliers.

What they say is that you should prove that you took adequate steps to guarantee this compliance so actually, the question is if there is no one single way you can follow, at least you should prove that you made all the necessary you ask the suppliers, you made assessments, you perform audits, you ask for this information, you are monitoring this information.

So it’s also about keeping track of how the relationship with your suppliers and partners is evolving and that’s all about the concept that you were also highlighting both Silvia and Alice, that is a process that is ongoing that you should continue to keep monitoring the data, you should have all the official documents actually, because you could be also sanctioned for something that happened a lot of years ago and if you don’t have the information to prove that’s a problem.

And on the other end, you should not do that only with your suppliers for the production, but you should also educate the final user, the customers about how to read this information and there’s also a question on that: “What are the data customers have to look at to make sure a company is acting sustainably?” 

So about this fact it is quite difficult to answer and I want also to pass the floor to you but from my standpoint, I think that it’s important that you look at what the company is communicating at 360° and if there is, for instance, a certification behind which proves that B corp, being a big corp company is a kind of certification, and also the fact that it is consistent, so this information this is a strategy that is keeping going and it’s not only one product, which is said to be sustainable. Would you like to add something to that?”

S: “First of all I completely agree, it’s a matter of processes. It’s a very complicated process as I was saying and you have to be reliable how can you just choose one way? 

There’s no unique law that guides us, we just have to find what fits the most to our company and follow what we have decided to choose.

In our case, we decided for instance to follow the GRI to report because we thought they were the most effective ones or to be followed and we decided to become B Corp.

There are always people complaining, there is always someone who says “oh it’s just a pin that you put on your chest” and that’s “it’s just another certification, it’s not something so serious, you pay for it” and it’s not just a matter of B Corp because stakeholders, a particular section of stakeholders, are complaining about anything. So it’s not just a matter of being serious, there is always something going on wrong for instance. 

On our side we respect animals, but we use synthetic materials, so there are a lot of people coming up saying: “you are polluting”. 

We are not perfect, we are a profit company, and we have to handle the situation. It means to communicate what we call the data that we collect, about our operations most sincerely and transparently, but of course, we have impacts, each one of us has an impact, In the morning, just putting our feet on the floor and turning the light off. 

It’s very easy to blame companies and the responsibility of proving what we’re doing is all on us and sometimes it’s difficult to demonstrate that we are serious, that we are engaged, that we deeply believe in what we’re doing. 

100%, total, perfect… this is something that doesn’t belong to a company, a responsible one, because if you are responsible, you know that you cannot reach perfection. 

It’s just a matter of limiting impacts and trying to work and conduct business most responsibly. This is what I call transparency and not doing greenwashing.”

A: “I agree with Silvia. We are for-profit corporations, all of us, all the B-corps are for-profit corporations. The thing is to use the profit for the right cause.

I think it’s not a matter of being for-profit, but how you produce that profit and if you are focused on a short-term perspective or a long-term perspective, to address the short-term issue. 

I think we should provide a way for companies to connect with multiple stakeholders because this would help companies operate with a different set of incentives and amplify their systematic vision.

If we embrace a systematic vision, we can easily understand how dangerous it is to maintain a short-term perspective, to gain profit in the short term.

Because the externalities caused by a company, to gain profit in the short term, get internalized by other companies in the same industry. 

So this results in a bigger loss for the whole system and from the measurement point of view I agree with Silvia: you have to choose a tool. We chose the BIA, which is very detailed. If you follow the path of the assessment and if you answer all the questions that the B certification gave to you, you are probably going to be sustainable, because you already proved it through the answers that you provided to the assessment.

We rely on the B Corporation certification, so I believe we, first of all, have to consider that tool as an indicator of sustainability.”

What do you think the biggest challenges for fashion companies will be?

M: “Absolutely and thank you, Alice and Silvia. I agree with the concept of systematic vision.

For doing that you should have some guidelines, some rules, and here it comes with a question for Veronica, which is about the new upcoming legislation, the EU textile strategy, which will also tackle greenwashing.

For those who don’t know, it’s new upcoming legislation that will regulate and set some guidelines for words and claim as “green” and “eco-friendly”, and slogan as “climate positive”, which needs to be proven by giving the evidence for that. 

There is also other legislation on that topic we mentioned: The Due Diligence, law which is in Europe, and the upcoming Fashion Act in New York, which also is asking for supply chain traceability and transparency because that’s the key. 

When you speak about communicating what you’re doing, that’s all about transparency so not only what you are doing, but also how you report on what you’re doing. 

I take back this question that asks: “What do you think the biggest challenges for fashion companies will be? What would you like to see in the new and upcoming policies?” 

Alicia was also mentioning potentially a fee for internalizing the negative externalities, for example ‘I pollute more, so I have to increase the price of the product because there are taxes on it’. 

Someone else is asking about which are the fines if you’re not compliant. 

Any law has different fines; I know for instance about the EU Due Diligence Law, which asks for a fine of up to two percent of the overall revenues if a company is not compliant but I pass the floor to Veronica.”

V: “From the legal perspective, most of the things here in Europe are related to the European green deal, the amendment, or the directive on consumer advertising law. The key is transparency.

Coming to the law I think that any company should first make a sort of assessment about their own business before choosing any kind of claims or strategy, because there are so many laws, even in Europe, and there is such an amendment going on about that. 

The first thing is to check and comply with your sector product-specific law, the one that applied to your specific products because sometimes they are specifically on that. 

The second thing to consider is consumer protection law, which is something that in Europe is closely related to, but it’s something that in every country is applied. 

Then right now there are guidelines; in each country, there are watchdogs that are active in this sector and they provide useful tools or examples about how to use and create your claims in compliance with the law. 

You need to assess first and then check the particular law applicable to your case. 

I also suggest you have a look at the UK guidelines because there is a sort of checklist here and I’ve found it very useful when I try to explain to companies what claims are correct, and there is these sort of Q&A sessions.”

Last tips to avoid (or fight) greenwashing

M: “I want to conclude because we said a lot about also about how to be compliant, but it’s not only important to be compliant but to be able to communicate in a unique way what you’re doing, what’s the story behind your product, what’s your identity because we cannot all communicate the same way because we have a different story to tell.

Veronica, you can at least mention the new and upcoming legislation, let’s say for preparing the audience for the next section we are going to have.”

V: “We have specific legislation in Europe, in Italy, and what I have mentioned in this panel is based on European legislation and I think that most of the legislation around the world that have something closely related to environmental claims is similar because transparency is the key.

You should not mislead the public, the consumer.”

M: “About transparency, one thing is extremely important: Fashion Revolution, the activist movement, has been published that there’s only 11% of the big brands that are publishing information about the raw material producers.

The majority of the industry is not publishing any information about the suppliers, for instance not transparent at all.”

V: “I think that the most important thing on that or most interesting one is that the European Commission is proposing several amendments to the unfair commercial practices directive and new practices will be added to the existing list of prohibited and fair commercial practices, a sort of blacklist.

New practices will include among others making generic vogue environmental claims like “environmentally friendly” “eco”, “green” or making an environmental claim about the entire product when it concerns only a certain aspect, a certain part of the product.”

M: “I think we can conclude by saying that we need to be clear, sincere, ourselves, and transparent so I think that’s the clue for today.”

If you want to know if your company is compliant or you want to do a 30-minute free consultancy with us about traceability and transparency, click here.