Cutting the BS on eco-friendly, non-toxic, and biodegradable
Why vague, misleading and irrelevant claims are greenwashing, too!
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544 said yes, we say thank you! In case you missed it: Members of the European Parliament have backed the proposal for a new directive on “empowering consumers for the green transition.”1 The proposed directive2 is part of the first circular economy package, along with the ecodesign regulation, construction products regulation and their own-initiative report on the EU strategy for sustainable and circular textiles.
We’ve got a quick summary for you:
🔹 The proposal of the directive on “empowering consumers for the green transition” was first published in 2022.
🔹 Under the current draft the use of general environmental claims like “environmentally friendly”, “natural”, “biodegradable”, “climate neutral” or “eco” are banned if they don’t come with backed-up evidence.
🔹 Climate claims that are based solely on carbon offsetting schemes are also supposed to be banned.
🔹 Misleading claims will be forbidden. Two examples: Claims about the whole product when it’s only true for a component of it; claims that a product will last a certain amount of time if that’s not true.
🔹 It also aims to simplify product information by only allowing environmental product labels that are based on official third party certification schemes or established by public authorities.
🔹What’s next: The Parliament and the member states will negotiate the final content and wording of the directive soon.
Even though it’s not legally binding for companies quite yet, it paves the way for anti-greenwashing and the EU Green Claims Directive that will further specify the conditions for making environmental claims in the future.
Recap
In March 2023 the European Commission published a proposal of a Green Claims Directive to fight greenwashing. We’ve summarized everything you need to know in our March issues.
What are the Goals of the Green Claims Directive? Who will have to follow the GCD? What will it cost? And what are the key takeaways of the proposal? Find all answers here.
We spoke to George Harding-Rolls from Changing Markets Foundation about his take on the EU Green Claims Directive proposal and which impact it will have on the market. Read the interview and our practical analysis of green claims here.
Vague claims: They make up a big part of green claims and use wordings that don’t have a legal definition. That makes them hard to pin down and rather meaningless. Because they create an impression of environmentally friendly behavior without actually supporting change.
Misleading claims: A claim which is considered misleading will depend on the circumstances of each case, and what misleads one group of consumers may not necessarily mislead others. A claim can be misleading even if it is partly true.
Irrelevant claims: Irrelevance is a little trickier than vague or misleading promises to notice. They are backed up by evidence and tell the truth to some extent but they are unimportant for the environmental performance of a product. Claims are also irrelevant when they are true but unhelpful to consumers trying to find environmentally preferable products.
Let’s look at some examples
Here are examples of vague, misleading, and irrelevant wording companies like to use in their communication.
1. Eco-friendly or environmentally friendly
You literally see this term everywhere. And it’s grown to be somewhat annoying–at least to us. So we appreciate this term being banned in the future. And here’s why: The term environmentally friendly doesn’t say much. It actually leaves us with more questions than answers.
How is it environmentally friendly? What does “friendly” even mean? What are the benefits? And what are the downsides? Because there’s no product that doesn’t have any harmful impact on the environment. As soon as resources are used, they have an impact. And while a product might be friendly to the environment, it doesn’t mean that its production is.
2. Recyclable
Sounds great in theory: As the fashion industry aims to become circular (which we are still far far away from) brands tend to slap the wording recyclable onto their products. And in some cases, when a product is made from mono materials (one fiber or one base material) it is recyclable in theory. But in most cases, it stops right there. Because textile-to-textile recycling doesn’t work at scale yet. Only 1 percent of textiles are recycled into new textiles because the infrastructure doesn’t exist.3 The rest of the textiles either end up in landfills, are burned or are downcycled into dead-end products like industrial rags.
So in most cases, brands should not use the term “recyclable”. The only exception: Brands that have implemented a reverse supply chain or give clear guidance on how and where to recycle their products.
The same is true for polybags (just stop using them and find alternatives!): They are mostly used to transport and cover pieces of clothing. They are oftentimes too small and fall through the grates of the sorting system and are not recycled.
3. Biodegradable
It sounds so good and we wish it wouldn’t be so complex. But it is, so let’s look at the term “biodegradable”. What’s good: It has a specific meaning. Biodegradable means something breaks down by the action of microorganisms.4 What’s bad: Saying something is “biodegradable” is as useful as saying something is “natural”. Apart from plastics that mostly photodegrade into microplastics, most other materials biodegrade somehow. The difference is just how long they take to break down, under which conditions they do so, and how much they contaminate in the meantime.
And there’s another issue:
Think of nature in the same way as an organism. A harmful chemical released into the environment in large amounts may be biodegradable, but it can still do harm if not properly diluted.
So know that biodegradable is a vague term, and there is no certifying agency to define or regulate it. Remember the federal or state government does not regulate the use of the word biodegradable, just as the words mentioned above, such as eco-friendly, are not regulated.
4. Non-toxic
This is another term that you may not expect to end up on a greenwashing list. Non-toxic is non-toxic, right? Sounds like a good thing. But any term used on a product label is only as good as its legal definition. And just like the other terms “non-toxic” is not regulated. Especially in the world of C2C Certified® and/or GOTS-certified fashion items “non-toxic” is used a lot to promote a product or explain that the used chemical products in wet-processing might be “non-toxic”. If you dilute the product enough under industrial terms the chemicals may not hurt you as a consumer or worker, but they are certainly not non-toxic. Textile chemical mixtures, also the ones having been toxicologically tested, do contain ingredients that have damaging effects on the environment and/or people.
As we explained above irrelevant claims tell the truth to some extent. But they don’t really say anything about the impact a product is having on the environment. How about some examples?
“non-GMO” label
We’re jumping into textile crop agriculture for a second but stay with us. Because agriculture is a big part of fashion as well! There’s a hot debate going on about whether genetically modified strains of produce cause environmental hazards in cotton cultivation or whether the amounts of synthetic and hazardous fertilizers as well as agricultural mono-methodologies are the actual cause.
For those who believe GMO varieties are not different from traditional hybrids, the “non-GMO” label is always irrelevant to the environmental performance of the product. On the other hand, for people who want to avoid genetically modified crops, knowing whether cotton is non-GMO is valuable. Then there are countries like Turkey where GMO crops are forbidden, so labeling Turkish cotton to be “GMO-free” as a positive outcome is misusing legality.
“Mulesing-free” wool
If the claim “mulesing-free” wool is used for Irish or Argentinian wool it is misleading and irrelevant because there are no fly strikes in South America or Europe which is the reason farmers might use this brutal and violent practice in Australia. So claiming to use “mulesing-free” wool sounds like a brand has implemented specific animal welfare schemes even though they are irrelevant for that specific material from that part of the world. It implies an ethical choice that doesn’t exist.
Want to know more examples of vague, misleading and irrelevant claims? We’ve got more coming your way in our pro issue next week. And we will share practical tips on how to avoid vague claims altogether. Don’t miss it by becoming a pro subscriber.
All the best,
Tanita & Lavinia
Have a topic or question in mind we should include in one of our issues? Drop us a mail (thecrisps@substack.com) and tell us all about it.
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European Parliament, press release (2023). Parliament backs new rules for sustainable, durable products and no greenwashing. https://www.europarl.europa.eu/news/en/press-room/20230505IPR85011/parliament-backs-new-rules-for-sustainable-durable-products-and-no-greenwashing (accessed 11.05.2023)
European Commission, Directorate-General for Environment, (2023). Proposal for a Directive on green claims. https://environment.ec.europa.eu/publications/proposal-directive-green-claims_en (accessed 22.03.2023).
Fontell, P., & Heikkilä, P. (2017). Model of circular business ecosystem for textiles.
European Environmental Agency. Glossary “biodegradable”. https://www.eea.europa.eu/help/glossary/eea-glossary/biodegradable (accessed 23.05.2023)