An Integrated Framework to Assess Greenwashing

Abstract

In this paper we examine definitions of ‘greenwashing’ and its different forms, developing a tool for assessing diverse ‘green’ claims made by various actors. Research shows that significant deception and misleading claims exist both in the regulated commercial sphere, as well as in the unregulated non-commercial sphere (e.g., governments, NGO partnerships, international pledges, etc.). Recently, serious concerns have been raised over rampant greenwashing, in particular with regard to rapidly emerging net zero commitments. The proposed framework we developed is the first actionable tool for analysing the quality and truthfulness of such claims. The framework has widespread and unique potential for highlighting efforts that seek to delay or distract real solutions that are urgently needed today to tackle multiple climate and environmental crises. In addition, we note how the framework may also assist in the development of practices and communication strategies that ultimately avoid greenwashing.

Full text

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Citation: Nemes, N.; Scanlan, S.J.;
Smith, P.; Smith, T.; Aronczyk, M.;
Hill, S.; Lewis, S.L.; Montgomery,
A.W.; Tubiello, F.N.; Stabinsky, D. An
Integrated Framework to Assess
Greenwashing. Sustainability 2022,14,
4431. https://doi.org/10.3390/
su14084431
Academic Editor: Roberta Costa
Received: 26 February 2022
Accepted: 28 March 2022
Published: 8 April 2022
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sustainability
Article
An Integrated Framework to Assess Greenwashing
Noémi Nemes 1, Stephen J. Scanlan 2, Pete Smith 3, Tone Smith 4, Melissa Aronczyk 5, Stephanie Hill 6,
Simon L. Lewis 7, A. Wren Montgomery 8, Francesco N. Tubiello 9and Doreen Stabinsky 10, *
1Department of Political Science, University of Vienna, 7/2nd floor, 1010 Vienna, Austria;
noemin80@univie.ac.at
2Department of Sociology and Anthropology, Ohio University, Bentley Annex 162, Athens, OH 45701, USA;
scanlans@ohio.edu
3Institute of Biological and Environmental Sciences, University of Aberdeen, 23 St Machar Drive,
Aberdeen AB24 3UU, UK; pete.smith@abdn.ac.uk
4Institute for Multilevel Governance and Development, Vienna University of Economics and Business,
Welthandelsplatz 1/D4, 1020 Vienna, Austria; tone.smith@a1.net
5School of Communication & Information, Rutgers University, 4 Huntington St,
New Brunswick, NJ 08901, USA; melissa.aronczyk@rutgers.edu
6Communication and Culture, Ryerson University, 350 Victoria Street, Toronto, ON M5B 2K3, Canada;
steph.hill@ryerson.ca
7Department of Geography, University College London, Gower Street, London WC1E 6BT, UK;
s.l.lewis@ucl.ac.uk
8Ivey Business School, Western University, 1255 Western Rd, London, ON N6G 0N1, Canada;
wmontgomery@ivey.ca
9Statistics Division, Food and Agriculture Organisation, Viale delle Terme di Caracalla, 00153 Roma, Italy;
francesco.tubiello@fao.org
10 College of the Atlantic, 105 Eden Street, Bar Harbor, ME 04660, USA
*Correspondence: dstabinsky@coa.edu
Abstract:
In this paper we examine definitions of ‘greenwashing’ and its different forms, developing
a tool for assessing diverse ‘green’ claims made by various actors. Research shows that significant
deception and misleading claims exist both in the regulated commercial sphere, as well as in the
unregulated non-commercial sphere (e.g., governments, NGO partnerships, international pledges,
etc.). Recently, serious concerns have been raised over rampant greenwashing, in particular with
regard to rapidly emerging net zero commitments. The proposed framework we developed is the
first actionable tool for analysing the quality and truthfulness of such claims. The framework has
widespread and unique potential for highlighting efforts that seek to delay or distract real solutions
that are urgently needed today to tackle multiple climate and environmental crises. In addition,
we note how the framework may also assist in the development of practices and communication
strategies that ultimately avoid greenwashing.
Keywords:
green claims; greenwashing; greenwashing framework; misleading/deceptive environ-
mental communication; net zero; public relations; selective disclosure; sustainability; transparency
1. Introduction
Awareness is growing around the world about deceptive or outright false environmen-
tal claims made by companies, non-profits, and even governments when communicating
their strategies on environment and climate issues. These claims can be used to promote
the organisations’ social status, relationships with consumers and employees, or short-term
profits, while avoiding making more substantive changes necessary to rapidly reduce nega-
tive impacts on the environment. Despite this growing awareness, greenwashing remains
widespread. A recent review of 500 global websites led by the UK’s Competition and Mar-
kets Authority and the Netherlands Authority for Consumers and Markets (as part of the
International Consumer Protection and Enforcement Network) showed that roughly 40% of
Sustainability 2022,14, 4431. https://doi.org/10.3390/su14084431 https://www.mdpi.com/journal/sustainability

Sustainability 2022,14, 4431 2 of 13
green claims fall into the category of greenwash. Most countries have regulations in place
for minimizing misleading claims, but most focus on commercial practices only. For exam-
ple, in the US, the Federal Trade Commission produced the FTC Green Guides [
1
]; the EU
has launched the Unfair Commercial Practices Directive [
2
] and a Guidance Document [
3
]
on its implementation; and in the UK, the Advertising Standards Association Codes [
4
]
have laid down requirements for responsible advertisement. The most recent effort is
the Guidance on Green claims code by the UK’s Competition and Markets Authority [
5
],
which aims to help businesses comply with the law when making environmental claims.
While non-business actors, non-profits and government activities go unregulated, even
within the ‘regulated’ business sector, the high percentage of greenwashing in advertising
suggests that companies feel sufficiently confident that they will not be held accountable
for their claims. Other than piecemeal efforts by NGOs, bloggers, and journalists–such as
the Guardian’s year-long series “tracking the unprecedented efforts to hold the fossil fuel
industry to account” [
6
] or ClientEarth’s Greenwashing Files [
7
]—greenwashing beyond
commercial practices remains largely unmonitored. Furthermore, accountability efforts, as
well as national regulations, often leave out non-commercial actors and non-advertisements
(e.g., pledges, partnerships, certifications), where greenwashing also occurs.
Significant deception and misleading claims have been identified in this sphere, with
some even embedded in law. A recent example is the EU taxonomy on sustainable fi-
nance, which lists controversial energy sources, among them ethanol and wood biomass,
as sustainable [
8
] while including gas and nuclear in the green taxonomy [
9
]. Sustain-
ability certification, when not conducted rigorously, can also be used as green cover for
corporations and governments to deepen the assault on ecosystems and social and indige-
nous rights. Such multi-stakeholder initiatives may give false environmental credibility
to so-called ‘sustainable’ or ‘more sustainable’ products/services, as recently reported by
MSI Integrity [
10
] in ‘Not Fit for Purpose’. Climate-neutral and net-zero claims similarly
may deceive people through purposefully vague formulations: the thousands of net-zero
commitments announced by governments and firms can be interpreted and implemented
in as many ways as there are actors who have committed to them.
The problem we address is that there is no universal definition of greenwashing or
standard of behaviour that would help to detect it. The purpose of this paper, therefore, is to
fill this gap in the recognition and understanding of misleading and deceptive environmen-
tal communication by providing a framework to assess greenwashing by organisations. At
the same time, we recognize that there are many actors committed to minimizing negative
environmental impacts of companies and organizations. A strong and coherent set of
guidelines such as those we develop can also help positive actions to be fully understood
and supported by the public.
The primary objective in this article is to develop a science-based assessment tool
to promote discussions around transparency and accountability, inform the public about
how they could be potentially misled with false solutions and pledges and help different
actors to avoid greenwashing. The integrated framework that we include in the linked
Supplementary Table S1 is based on (a) integrating existing theoretical greenwashing
frameworks and the different types, varieties and so-called ‘sins’ of greenwashing that
the literature has presented to date, and (b) developing it further to create an actionable
framework to assess greenwashing efforts by any actors. Along with the assessment
framework, we provide an operational definition of greenwashing, which is intended to
encompass a variety of misleading communications and practices that intentionally or not,
induce false positive perceptions of an organisation’s environmental performance. In doing
this, we promote dialogue that importantly fine-tunes the meaning of greenwashing as a
complement to determining the methods we propose for assessing it.
2. Materials and Methods
We conducted an extensive review and qualitative analysis of the academic research
literature to identify the main types or varieties of greenwashing and the different indicators

Sustainability 2022,14, 4431 3 of 13
or questions that have been offered to test for its presence. We were mostly interested
in papers that focused on typologies of greenwash and detecting greenwashing, and we
undertook a multi-step process to identify and analyse these. In doing so, we focused on
the academic literature but also searched practitioner outlets and resources to ensure our
review was systematic.
In the first step of our analysis, we identified three prominent articles and reviews for
synthesis in our framework development. We did not intend to replicate recent systematic
academic reviews of the greenwashing literature (e.g., [
11
–
13
]). Instead, we sought to build
on their outcomes and analysis as a basis from which to extend the limited research on
identifying and detecting greenwashing. Their resultant subsets of literature formed the
nucleus of our overview of literature and the basis of our framework development, as
described below.
First, Lyon and Montgomery [
11
] reviewed and synthesized the multidisciplinary
research on greenwashing and reviewed 34 papers in three categories: drivers of greenwash;
varieties of greenwash and the impacts of greenwash. Because of our research objective,
we focused merely on the literature that they included while discussing the different
varieties of greenwash. Second, Gatti et al. [
12
] searched for the keywords “greenwash”
and “greenwashing” in the titles and abstracts of English articles between the period 1995
and 2018. The authors then conducted a qualitative content analysis to assess the core
findings and identified the following categories of research: the meaning of greenwashing;
the antecedents and drivers of greenwashing; the consequences of greenwashing; how to
reduce greenwashing; and how to detect greenwashing. For our research purposes, we
then focused on those articles which Gatti et al. identified within the category of “how to
detect greenwashing”. Third, de Freitas et al. [
13
] also conducted a systematic review on the
concepts and forms of greenwashing using the keywords of “greenwash”, “greenwashing”
and “greenwasher” in the academic search engines of Web of Science and Scopus. The
authors searched for these keywords in the titles, abstracts, introductions and conclusions
and identified a list of 67 publications between 2009 and 2018. Similar to our objectives, de
Freitas et al. also looked for the phenomenon characteristics and typology of greenwashing,
and out of the 67 documents, found 17 that provided insights on these aspects.
In the second step of our methodology, we wanted to move beyond scholarly articles
on the issues of greenwashing and its detection and so we conducted a thorough internet
search (using Google) with the keywords “greenwash checklist”, “greenwash indicators”
and “greenwashing frameworks” to include non-academic and practitioner sources. Here,
we searched for resources and organizations that offered criteria or checklists to help
assess/guide companies to avoid greenwashing. Many of these (e.g., [
14
–
16
]) had already
been identified and highlighted in the academic articles analysed in our review in the prior
step. However, through our search process we were able to add additional practitioner
resources (e.g., [
17
–
19
]) that had not been identified in prior literature. These helped us to
inform and develop our analysis and novel greenwashing framework.
Finally, as a third step, we also investigated the legal contexts within the EU, the UK,
and the US and included in our framework insights from the guidelines that have been
established in those governments to help companies to avoid misleading environmental
claims in their advertisements and other environmental communications. All these different
sources formed the backbone of our framework especially with regards to determining the
various varieties of greenwashing and their descriptions (included in the first and second
columns of the Supplementary Table S1).
During this review we found that academics have not yet come up with a single,
widely agreed upon and applicable method of measuring greenwashing objectively. One
of the pioneers in identifying and analysing greenwashing was the Center for Media
and Democracy founded by John Stauber in 1993. Their books [
20
,
21
] and other efforts
paved the way for investigative research into greenwashing and related deceptive practices
and their effects on consumers. Over the last decades, extensive work has been done to
categorize and quantify product-level greenwashing. For example, Gillespie [
22
] identified

Sustainability 2022,14, 4431 4 of 13
“ten signs of greenwash”, ranging from “fluffy language,” words or terms with no clear
meaning such as “eco-friendly”, to “outright lying,” as in totally fabricated claims or data.
The TerraChoice Environmental Marketing [
14
] categorized product-level greenwashing
into “seven sins”. These range from the “sin of the hidden trade-off”, committed by
suggesting a product is green based on an unreasonably narrow set of attributes without
attention to other environmental issues, to the “sin of fibbing”, which is committed by
making false environmental claims. The other sins are the sin of no proof; sin of vagueness;
sin of irrelevance; sin of lesser of two evils; and sin of worshipping false labels.
Greenpeace [
15
] defined four greenwashing detection criteria: dirty company, ad
bluster, political spin, and “it’s the law, stupid!”. In 2007, EnviroMedia Social Marketing in
collaboration with the University of Oregon implemented the “Greenwashing Index Scoring
Criteria” and a tool was made available on the internet (www.greenwashingindex.com,
accessed on 17 February 2022) which allowed users to assess the amount of greenwashing
in ads claiming to be green. They used the following criteria in their assessment: the
ad misleads with words; the ad misleads with visuals and/or graphics; the ad makes a
green claim that is vague or seemingly unprovable; the ad overstates or exaggerates how
green the product/company/service actually is; and the ad leaves out or masks important
information, making the green claim sound better than it is.
Gallicano [
23
] created the first integrated framework based on synthesizing the meth-
ods by four organisations used for assessing greenwashing claims (Greenpeace, the En-
viroMedia Social Marketing and the University of Oregon, TerraChoice Environmental
Marketing (now Underwriters Laboratory) and the Committee of Advertising Practice).
The framework developed by Gallicano consisted of seven main themes: Skeleton in the
closet; The Right hand isn’t talking to the left hand; Magic Tricks, Larger than Life; May I
have the definition please?; Law and order; and Truth and Fiction. In addition, a description
of the meanings of each of these is provided alongside an explanation of their significance.
This framework allowed comparisons and contrasts of the public environmental criticisms
using the case of Starbucks’ online information and corporate social responsibility reports
(see appendix of Gallicano [23]).
Next, focusing on conceptualization and theoretical development, Lyon and Mont-
gomery [
11
] synthesized the research on greenwashing and highlighted several varieties
of greenwash. Importantly they noted that the literature was not mature enough to have
identified all its forms: Selective disclosure; Empty green claims and policies; Dubious
certifications and labels; Co-opted NGO endorsements/partnerships; Ineffective public
voluntary programs; Misleading narrative and discourse; and Misleading visual imagery.
In presenting these ideas the authors provided great insight into understanding the many
definitions of greenwashing and its various forms, contributing to greater clarification of
the concept, and providing tools for understanding its presence.
Zanasi, Rota, Trerèand Falciatori [
24
] took this a step further by developing an
analytical tool that includes a list of indicators derived from several different organisations
(Greenpeace, EnviroMedia Social Marketing and the University of Oregon, Terrachoice,
Futerra) and authors. This work covers a broad range of sustainability dimensions as
well as offers communication suggestions in order to avoid greenwashing, focusing on the
agrifood sector in particular. The authors suggest a number of indicators for greenwashing
assessment including: Analysing the entire product’s Life Cycle; Ad contents should be
accessible, complete and verifiable; The language should be understandable and non-
misleading; Communicate sustainable activities only when they are effective, meaningful
and voluntary; Involve/engage; Do not use misleading “green” images; and Choose
reliable third party certification schemes. They suggest that further studies should weigh
the different greenwashing indicators in order to appreciate their relevance in contributing
to the overall level of meaningful communication on the subject.
Taken together, these various evaluation tools and frameworks from both the academic
literature and monitoring organisations provide a foundation for our work here. In addition
to examining national guidelines on green marketing (e.g., [
1
,
2
,
4
]), in our framework we

Sustainability 2022,14, 4431 5 of 13
mostly draw on sources from TerraChoice Environmental Marketing [
14
]; EnviroMedia
Social Marketing and the University of Oregon [
16
]; BSR & Futerra [
17
]; Gillespie [
22
];
Greenpeace [
15
]; Gallicano [
23
]; Lyon & Montgomery [
11
]; Parguel, Benoit-Moreau and
Russell [
25
]; Berrone [
26
]; Scanlan [
27
]; Siano et al. [
28
]; Contreras-Pacheco and Claasen [
29
];
Zanasi et al. [
24
]; and Sourcewatch [
18
]. We discuss the integration of these ideas in the
section that follows, seeking to build on their work with our assessment framework.
3. Results
3.1. Greenwashing: Definition and Varieties
As a concept, greenwashing has been examined from a number of academic disci-
plines in addition to being a part of conversations among various government bodies
and non-governmental organisations. Research contributing to its conceptualization and
understanding has come from the fields of business (including advertising, ethics, and
marketing), media and communications, environmental studies and management, produc-
tion engineering, law, and the social sciences (including economics, geography, political
science, psychology, and sociology) among others. Given the diversity of perspectives
that are a part of the conversation, it should come as no surprise that no single definition
of the concept has been universally accepted. Furthermore, as greenwashing becomes
increasingly important and attracts more attention, definitions continue to evolve, therefore
presenting a moving target of sorts as policymakers, practitioners, and scholars discuss
the issue.
What has emerged instead is a collection of definitions that are connected through
overlapping ideas that reveal a number of core elements of the concept or ways that it
manifests itself. Greenwashing can therefore take on multiple forms and reflect a variety of
components of interest that present both objective and subjective realities. In this paper, it is
not our intention to resolve debate over what definition is best nor develop what we believe
to be the universal standard. We instead can refer the reader to a number of important
academic studies that have done this in a far more thorough manner than what we are able
to do here including de Freitas Netto et al. [
13
]; Gatti et al. [
12
]; Lyon and Montgomery [
11
];
or Seele and Gatti [
30
]. We simply want to enable a basic understanding of the concept and
its various manifestations for the reader while presenting a simple definition that can serve
as a benchmark for using the framework that we have developed to assess its prevalence.
The Appendix Acontains a collection of several definitions for greenwashing. Re-
flecting the larger conversation on the topic, these come from a range of academic analy-
ses [
13
,
31
–
34
], consumer organisations [
19
,
35
], government entities [
3
,
36
], media [
37
,
38
]
and non-governmental organisations [
18
,
39
] among others. In addition, definitions of the
concept are also quite common from various dictionary or encyclopaedia sources [
40
], with
Becker-Olsen and Potucek [
41
] providing a particularly meaningful definition given the
corporate social responsibility context in which it appears:
Greenwashing refers to the practice of falsely promoting an organisation’s environ-
mental efforts or spending more resources to promote the organisation as green than are
spent to engage in environmentally sound practices. Thus, greenwashing is the dissemina-
tion of false or deceptive information regarding an organisation’s environmental strategies,
goals, motivations, and actions.
An often-used definition of greenwashing comes from the marketing and consulting
organisation TerraChoice, which is now a subsidiary of Underwriters Laboratories [
14
]:
“Greenwashing is the act of misleading consumers regarding the environmental practices of
a company or the environmental benefits of a product or service”. This definition captures
the essence of the core ideas that are central to the many available definitions, thus reflecting
the most important themes in its conceptualizations. Furthermore, complementing its
“seven sins of greenwashing” and examples used to identify it (see [
42
]), TerraChoice’s
conceptualization and application connect well with the framework we develop here.
New empirical analyses of greenwashing are constantly emerging in the wake of seem-
ingly expanding consumer demands for corporate accountability and social responsibility

Sustainability 2022,14, 4431 6 of 13
alongside concerns about climate change and the environment. Furthermore, theoreti-
cal considerations have evolved in a way that requires a continual reassessment of the
definition and forms of the concept. For example, definitions and research on the topic
typically has viewed greenwashing as a deliberate corporate action fraught with misleading
elements, focused on the deception of stakeholders. More recent literature on greenwash-
ing suggest that it is not necessarily deliberate and furthermore encompasses a range of
phenomena that go well beyond simply the disclosure of information (see [
11
,
25
]) though
of course others (e.g., [
37
,
43
]) may disagree regarding the intentionality dynamic thus
indicating the importance of ongoing debate.
In another example of the concept’s evolution, the literature also shows that just like
corporations, NGOs, and governments can engage in greenwashing: in fact, they may often
serve as partners in corporate greenwashing [
11
] or manage public perception of a specific
policy or various programs [
38
,
44
]. Sometimes “greenwashing” is not out of malice, but
instead due to ignorance of environmental issues and environmental laws. It can also be
a result of poorly conceived public relations efforts, which lead to the promotion of false
or misleading environmental claims. In addition, the study of greenwashing is primarily
concerned with environmental issues, a notion that Gatti et al. [
12
] (p. 6) reinforce in their
finding that 61.6% of the studies they reviewed felt this exclusively to be the case. However,
there are far reaching implications, and as this same study further notes, 38% believe that
the concept relates to social issues as well (Ibid). For this reason and for purposes of both
developing and applying a framework for its assessment, it is essential to consider the
consequences that greenwashing has with regard to interface between the environment
and society and its connections to additional components that are important to corporate
social responsibility (see [12,45]).
Finally, building on the emergent literature and for the purpose of framework de-
velopment and assessment, we have developed the following working definition, which
we derive from the sources noted above: greenwashing is an umbrella term for a variety
of misleading communications and practices that intentionally or not, induce false posi-
tive perceptions of an organisation’s environmental performance. It can be conducted by
companies, governments, politicians, research organisations, international organisations,
banks and NGOs too and it can range from slight exaggeration to full fabrication, thus
there are different shades of greenwashing. The Supplementary Table S1 presents the 13
main varieties/themes of greenwashing. Table 1below is intended to reflect a sample of
definitions that appear in the framework.
Table 1. Glossary of terms appearing in the integrated framework to assess greenwashing.
Terms Definitions
Claim
Evidence that organisations use to prove their point. Claims can take the form
of verbal or written statements, pictures, reports, ads, but also collective
aspirations by stakeholder groups; pledges; codes of conduct that define
specific production or sourcing practices; and sectoral standards including
principles, criteria and forms of verification agreed on by several stakeholders
within a sector.
Greenwashing
An umbrella term for a variety of misleading communications and practices
that intentionally or not, induce false positive perceptions of an organisation’s
environmental performance.
Organisation
An entity–such as a company, a consultancy, bank or an association (e.g.,
NGO)–comprising one or more people and having a particular purpose. For
the purposes of the framework, governments and sub-national actors are also
treated as organisations.

Sustainability 2022,14, 4431 7 of 13
Table 1. Cont.
Terms Definitions
Transparency
A form of public exposure used to display communicative power. Assessments
of transparency go beyond mere availability of information [46]. They must
consider the means of transparency (e.g., self-disclosure versus legal
requirement), the context of transparency (e.g., Through whose labour is the
transparency achieved? Who controls the timing, scope, and particularities of
information distribution?) and the beneficiaries of transparency (e.g.,
self-branding exercise or civic obligation)? [47]
3.2. Integrating Greenwashing Frameworks
Greenwashing frameworks, guidelines and checklists have been developed by several
actors, among them academics, NGOs, and business consultants for a variety of reasons.
BSR & Futerra [
17
] in their practical manual for companies on greenwashing, offered a
useful categorisation for avoiding the various types of greenwash: impact (ensuring it’s
real), alignment (building support internally and externally) and communication (ensuring
it is accurate). They advised that when an actor wants to communicate a message about
environmental issues, (a) it should be based on real, significant impact; (b) it should be
aligned with multiple functions within the organisation and the integrity of claims should
be checked by credible third parties; and (c) the communication should be focused on clarity
and transparency. We have decided to follow these three categories within our framework
as they capture all the various types and varieties of greenwashing in a meaningful way.
The resulting framework consists of 13 themes, describing the various types of claims
used in greenwashing, all taken from existing literature (see first column of the Supple-
mentary Table S1 for the list of themes). First, we have included themes in our framework
that appeared in several research publications. Because some of them have been named
differently by the various authors, we use names that best reflect the descriptions of the
themes. Second, we included the descriptions of the different themes (second column of the
Supplementary Table S1). Next, we integrated various statements, indicators, and questions
that either the scientific literature on greenwashing examined or those non-academic discus-
sions of greenwashing have deemed to be important (third column of the Supplementary
Table S1) regarding the previously described themes. Where the different sources offered
some statements that could be changed into the format of a question, we have integrated
these, sometimes with modification so that the question is applicable for testing within
the framework.
We discovered a large gap in the academic literature. While several authors have
referred to different forms of greenwashing, in some themes (most noticeably in ‘dubi-
ous certifications & labels’ and ‘co-opted endorsement’), we did not find corresponding
questions, statements or criteria that could help to assess whether an actor engages in
greenwashing. For instance, under what circumstances could certification schemes support
greenwashing? Similarly, when could national agencies or NGOs be accused of contributing
to corporate greenwashing? We have not found answers in the literature to these questions.
Our framework therefore offers a first attempt to incorporate indicators in the fields where
current literature on greenwashing has not included guidance on specific themes, issues,
or organisations.
In addition, we have not found any attempt in the academic literature to give weights
to the different indicators in greenwashing frameworks. One option is to choose core
indicators which could be weighted more heavily than other indicators. Another option
to avoid the weighting of indicators (which is prone to subjective judgment) is to give
each question a point and include more questions in some themes than in others. This
would mean that some themes have greater value in the potential overall score that results
by virtue of their multiple assessment dimensions. However, which themes weigh more
is also a subjective decision. A final option is to agree on themes having equal weight,
meaning that the weight of indicator questions is different depending on the number of

Sustainability 2022,14, 4431 8 of 13
questions within one theme. One of the disadvantages of this last option is that themes
like outright ‘lying’ do not have a stronger moral weight than simply using ‘jargon’ or
‘misleading symbols’ in communication. This makes equal weighting of themes difficult to
justify. However, it is similarly difficult to give more weight to themes with more questions,
when for example out-right lying is captured with a single indicator. Because of the lack of
any attempt to assign weight to the different indicators in greenwashing literature, and the
subjectivity that is needed to decide on various weights, we have decided not to assign any
score or weight to the different indicators and themes.
Finally, no literature was found with proposed methods for accounting for the dif-
ferent degree or severity of the potential impact of greenwash. This is important in that
greenwashing can have different impacts depending on the type, scope, and severity of
the application. For example, deflecting the serious consequences of fossil fuels on climate
change through influence peddling and denial seems far more severe in scope than simply
using a green image in a magazine ad. The results of greenwashing remain the same,
however. Our framework can be applied to real cases to pinpoint the obvious and likely
greenwashing, as well as to offer a tool that can help an actor to more robustly communicate
positive actions taken while avoiding any shade of greenwashing.
4. Discussion: How to Use the Framework
The framework is intended to be an operational tool, not just an academic exercise.
It can be used as a tool by organisations as a guide to communicating environmental
claims while avoiding greenwashing, and by users more widely to distinguish genuine
green claims from false and misleading statements. It can be a useful tool for activists,
NGOs, journalists, researchers, policymakers or others who want to systematically assess
an organisation’s claims for potential greenwashing within a unified and consistent analysis
framework. Some claims might intuitively seem like greenwashing, but one might not know
how to rigorously assess whether they are or not. This framework provides a structured
way to ask questions about the different varieties of greenwashing to evaluate whether the
organisation under assessment could be considered as engaging in greenwashing or not. It
is not meant as a framework to benchmark organisations, but simply to analyse whether
they are involved in greenwashing.
The way to use this framework is therefore quite straightforward: one needs to
find a claim that is potentially a greenwash and check it against the list of indicator
questions contained in the framework. Some questions will be irrelevant to the claim, in
which case they can be ignored. Others may not be known or publicly available to the
person doing the assessment (e.g., the marketing budget of a corporation) and thus these
questions can be answered with an ‘unknown’. Often, various sources need to be consulted
in order to answer questions, including the organisation’s own website, social media,
ads in radio/TV/print, as well as recent sustainability or annual reports and financial
statements. In the end, if there is any question answered with a ‘yes’ in the framework the
organisation is already to some extent involved in greenwashing. As mentioned above,
the framework is not meant to analyse the degree of greenwashing-hence if the questions
(even if some of them) within a theme/variety of greenwashing is answered affirmatively
(so the claim is a greenwash according to some indicator questions), the organisation
already has fallen prey to greenwashing. Finally, some questions cannot be answered with
a straightforward yes/no, thus an in-between answer, with the response ‘likely greenwash’
has been incorporated to better account for such situations and highlight areas needing
additional research or scrutiny.
This framework provides a comprehensive tool for evaluating the environmental
claims of organisations. It is intended to be used to evaluate specific claims and therefore
has limited usefulness to questions of societal level systems and structures. For instance,
the greenwashing framework does not address questions of economic growth and overcon-
sumption, product quality, labour, inequality, or social justice. Likewise, this assessment
tool does not account for different sizes of organisations, particularly small organisations,

Sustainability 2022,14, 4431 9 of 13
and their differing material abilities. Nor does it address broader questions about the
usefulness of certification schemes, which must be assessed on their own merits. This
framework is best used to assess the public environmental claims made by organisations
and uncover lies, half-truths, and misleading claims.
The tool is also meant to be a dynamic, living framework that needs to be fine-tuned
and revised regularly as more and more claims are being tested. It cannot be a one-time
product but needs to evolve alongside various environmental communication strategies
and practices. Thus, the authors of this paper, as members of the CSSN Working Group on
Spinning Climate Change, would like to regularly adapt the framework as more claims are
being tested.
5. Conclusions
This paper presents an integrated framework to support avoiding greenwashing by
actors of any kind, including corporations, governments, and other organisations. The
framework collects in one set of greenwashing themes a broader range of indicators linked
to possible sources of greenwashing and could support effective sustainability policies and
genuine green marketing and communication strategies at the level of any organisation.
In addition, it may also be used by others wishing to hold various actors accountable
for the claims they make. In this regard, the framework can be seen as a monitoring
tool of sorts by academics, activists, or consumers, among others, who are interested in
better understanding the practice of greenwashing and informing stakeholders of the
practice. Scoring of different greenwashing indicators has so far not been attempted in
literature. However, greenwashing can already be identified when an indicator question is
answered with a ‘yes’. Zanasi et al. [
24
] pointed out that further studies are necessary to
weigh the different green marketing and greenwashing indicators in order to understand
their relevance in contributing to the overall level of correct communication. Since such
studies are currently lacking, this paper focussed on (a) defining the different varieties of
greenwashing by different actors that have been mentioned in the academic literature, and
(b) presenting a tool to support the assessment of diverse green claims by any actor. This
framework potentially provides a useful basis for a numerical greenwashing index—used
internally or externally—to better understand the degree of greenwashing in various cases.
Furthermore, the phrasing of the different greenwashing indicator questions, as well as
fine-tuning the various answers, could be improved by testing the framework on different
green claims.
Persistent vigilance, especially of the fossil fuel industries and those relying heavily
on the use of fossil fuels (e.g., transport, construction, utilities, mining and processing,
manufacturing, agriculture, fashion, etc.) is essential to closely scrutinise messages and
call into question blatant misinformation [
27
]. In the era of “alternative facts”, there
is a pressing need for regulation of claims and accountability regarding science versus
“fake solutions” on environmental issues. Social movements and NGOs play a role in
this, but there is also an important place for the news media and government agencies
to contribute. This framework offers a mechanism to develop a solid evidence base for
identifying greenwashing not just of corporations, but of ill-designed government policies,
of certification schemes giving credibility to business-as-usual practices, and of any other
actors claiming exaggerated environmental benefits. Close scrutiny is especially needed
now in the rush to tackle the climate and biodiversity crises in which we find ourselves.
Supplementary Materials:
The following supporting information can be downloaded at: https://
www.mdpi.com/article/10.3390/su14084431/s1, Table S1: Integrated Framework of Greenwashing.
Author Contributions:
Writing—original draft, N.N., S.J.S., P.S. and T.S.; writing—reviewing and
editing, M.A., S.H., S.L.L., A.W.M., F.N.T. and D.S.; supervision, D.S. All authors have read and
agreed to the published version of the manuscript.

Sustainability 2022,14, 4431 10 of 13
Funding:
This research was funded by the Department of Political Science at University of Vienna,
Austria and the Institute at Brown for Environment and Society, USA, in association with Climate
Social Science Network.
Institutional Review Board Statement: Not applicable.
Informed Consent Statement: Not applicable.
Data Availability Statement: Not applicable.
Conflicts of Interest:
The authors declare no conflict of interest. The funders had no role in the design
of the study; in the collection, analyses, or interpretation of data; in the writing of the manuscript,
or in the decision to publish the results. The views expressed in this publication are those of the
individual authors and do not necessarily reflect the views or policies of their respective institutions.
Appendix A. Collection of Greenwashing Definitions
Definition
“The act of disseminating disinformation to consumers regarding the environmental practices of a company or the environmental
benefits of a product or service” [31], p. 424.
“Greenwashing refers to the practice of falsely promoting an organisation’s environmental efforts or spending more resources to
promote the organisation as green than are spent to actually engage in environmentally sound practices. Thus, greenwashing is the
dissemination of false or deceptive information regarding an organisation’s environmental strategies, goals, motivations, and
actions” [41].
“Disinformation disseminated by an organisation so as to present an environmentally responsible public image” [40].
“Greenwashing is when a company or organisation spends more time and money on marketing themselves as environmentally
friendly than on minimizing their environmental impact. It is a deceitful advertising gimmick intended to mislead consumers who
prefer to buy goods and services from environmentally conscious brands” [37].
“(1) The phenomenon of socially and environmentally destructive corporations attempting to preserve and expand their markets by
posing as friends of the environment and leaders in the struggle to eradicate poverty. (2) Environmental whitewash. (3) Any
attempt to brainwash consumers or policy makers into believing polluting mega-corporations are the key to environmentally sound
sustainable development (4) Hogwash [39].
“greenwashing is taken to mean two main things. It can be when companies—usually mega corporations and sometimes
politicians—try to hide or cover up their less-than-stellar environmental records with a grand, public gesture towards green causes
the other type of greenwashing is where companies and brands use words like ‘green’, ‘sustainable’, ‘eco-friendly’, or ‘vegan’
simply as a marketing ploy, without any deep interrogation over what those terms actually mean. And crucially-without any
accountability for their actions” [38].
The authors note two different major classifications of greenwashing, including “product/service level claim greenwashing, which
uses textual arguments that explicitly or implicitly refer to the ecological benefits of a product or service to create a misleading
environmental claim” [13:7] while “executional greenwashing suggests nature-evoking elements such as images using colors (e.g.,
green, blue) or sounds (e.g., sea, birds). Backgrounds representing natural landscapes (e.g., mountains, forests, oceans), or pictures
of endangered animal species (e.g., pandas dolphins) or renewable sources of energy (e.g., wind, waterfalls) are examples of
executional nature-evoking elements” [13], p. 10.
“the act of misleading consumers regarding the environmental practices of organisations (firm-level greenwashing) or the
environmental benefits of a product or service (product-level greenwashing)” [32], p. 66.
“Greenwashing is the process by which organisations spread misleading perceptions about their products or services that suggest
they are more environmentally responsible than is the reality. The practice of greenwashing is used regularly by corporations,
governments, and other entities to deceive the public into believing that they are doing more for the environment than they truly
are in order to gain better public perception” [35].
“Greenwashing is used to describe the practice of companies launching adverts, campaigns, products etc. under the pretence that
they are environmentally beneficial, often in contradiction to their environmental and sustainability record in general” [19].

Sustainability 2022,14, 4431 11 of 13
Definition
“The expressions ‘environmental claims’ and ‘green claims’ refer to the practice of suggesting or otherwise creating the impression
(in a commercial communication, marketing or advertising) that a good or a service has a positive or no impact on the environment
or is less damaging to the environment than competing goods or services. This may be due to its composition, how it has been
manufactured or produced, how it can be disposed of and the reduction in energy or pollution expected from its use. When such
claims are not true or cannot be verified, this practice is often called ‘greenwashing’. ‘Greenwashing’ can relate to all forms of
business- to-consumer commercial practices concerning the environmental attributes of goods or services. According to the
circumstances, this can include all types of statements, information, symbols, logos, graphics and brand names, and their interplay
with colours, on packaging, labelling, advertising, in all media (including websites) and made by any organisation, if it qualifies as
a “trader” and engages in commercial practices towards consumers” [3], p. 95.
“Greenwashing is the process of conveying a false impression or providing misleading information about how a company’s
products are more environmentally sound. Greenwashing is considered an unsubstantiated claim to deceive consumers into
believing that a company’s products are environmentally friendly” [43].
“greenwash can be characterized as the selective disclosure of positive information about a company’s environmental or social
performance, while withholding negative information on these dimensions” [33], p. 5.
“the word greenwash is used to cover any communication that misleads people into adopting overly positive beliefs about an
organisation’s environmental performance, practices, or products the important phenomenon of misleading environmental
communication” [11], p. 226.
“Greenwashing is the practice of promoting environmentally friendly programs to deflect attention from an organisation’s
environmentally unfriendly or less savory activities” [34], p. 19.
Focus on “executional greenwashing whereby nature-evoking elements in the ad execution may induce false perceptions of a
brand’s greenness, whether intentionally or not on the part of the advertiser” [25], p. 108.
“Greenwashing is the unjustified appropriation of environmental virtue by a company, an industry, a government, a politician or
even a non-government organisation to create a pro-environmental image, sell a product or a policy, or to try and rehabilitate their
standing with the public and decision makers after being embroiled in controversy” [18].
“The act of misleading consumers regarding the environmental practices of a company or the environmental benefits of a product
or service” [48].
“Communication that misleads people (e.g., consumers and stakeholders) regarding environmental performance/benefits by
disclosing negative information and disseminating positive information about an organisation, service, or product” [49],
pp. 372–373.
“Greenwashing is the act of misleading consumers regarding the environmental practices of a company or the environmental
benefits of a product or service” [42].
“The practice of advertising a product or process as “green” or environmentally friendly, when the product really is not, or does not
achieve the advertised marketing claims. A false or misleading picture of environmental friendliness used to conceal or obscure
damaging activities” [36].
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