Digging the dirt on greenwashing in the cosmetics industry: 4 key rules to make sure you aren’t pretending to be greener than you are…

Belinda Carli, 06/04/2022

Consumers love to feel that they are doing their part for their environment and are commonly drawn to natural claims on products. Over recent years, we’ve seen a huge increase in ‘green’ and natural claims, including sustainability and all sorts of eco-conscience statements – but how do you know when they are true or not, and more importantly, how do you make sure your brand doesn’t cross the line into non-compliance, but still maintain its competitive edge – especially when it really is as green as you claim?

‘Greenwashing’ has become such a problem that the UK have released their green claims code; NZ have their environmental claims guidelines; Australia has their environmental and organic claims code; USA have their green guides; and Canada have their environmental claims guidance. EU also have their green claims code in draft stage.

One of the problems we find, when talking with brands, is they often don’t realise they are overusing green claims, all too regularly referring to other brands where similar misleading claims are made. They may also not understand ingredients or the supply chain properly, so in some cases, are making claims they believe to be true without checking their facts properly first. Either of these ‘accidental’ cases can still land you in hot water with a regulator!

This blog will consider the key issues with green claims, when they are overused, and how your brand can build credibility rather than be another ‘me-too’ with greenwashing.

While the specific wording of the various green claims guidelines or codes around the world may vary, the overarching principles of the rules does not. Here are key concepts to adhere to.


1. Claims must be truthful and understandable

This one may sound simple, but it’s the number one rule we see broken. Make sure you:  

  • do not use fancy terms or twist your words to make your company or products sound greener than they actually are
    • for example, we see claims such as ‘sustainably sourced ingredients’, when they may only use one or a few of these types of ingredients in a low input. The rest of their ingredients may not even be traceable!
    • it is wrong to imply that most or all of your ingredients have an attribute they do not – make sure you are specific.
  • do not re-communicate what you see another brand doing
    • the overuse of blanket statements and logos implying a product is green or sustainable is commonly done by small brands trying to ‘keep up’ with other brands making similar claims/using similar icons.
    • just because another brand says or does something, does not make it acceptable for your brand to do the same – if a regulator investigates your claims and activities, trying to use the excuse, ‘but Smith Brothers do the same,’ will not get you off the hook!
  • do not make blanket statements without qualifying how you achieve those items
    • for example, the terms ‘green’, ‘sustainable’, ‘eco-friendly’ (and others like this) are vague and can lead a consumer to believe a product is all natural, totally sustainable, or completely eco-friendly, when parts of it may not be.
    • blanket statements like these should either be qualified with proof based on evidence you hold, or be reworded to be specific and accurate.
    • be careful of using logos or symbols as a way of showing these blanket statements too – it is still implying the whole of the product achieves the statements made. Make sure it is true or be specific about which components these terms apply to.
    • consider also the entire lifecycle of the product – blanket statements may not apply to the product throughout the life of the product – from its sourcing to disposal – and if they don’t, your claim is misleading. If you can’t show the appropriate evidence from cradle to grave, don’t make the blanket statement. 
  • don’t put ‘source’ ingredients in brackets after an ingredient if there are other sources used in that ingredient you are not claiming.
    • for example, we often see: cocamidopropyl betaine (from coconuts) – this is incorrect! Part of it may come from coconut oil or palm oil, but in all cases, it contains synthetic ingredients too. If you want to put a source material in the bracket, you should be naming all source materials – including the synthetic ones.


How a brand leader uses truth and understandable messages to their advantage:

  • use third party certification and logos where possible to prove the green statements made by your product OR provide accurate % inputs for the natural or organic content.
  • check all packaging components and use the correct terminology if making claims about its biodegradability, sourcing, and recycling status.
  • don’t make blanket statements – make specific statements instead. Your consumer actually prefers this, and it sets you apart from other companies where this is not done.
  • don’t use fancy terminology or wording your consumer may not understand – use truthful, transparent statements to earn their trust.


2. Claims should be accurate based on evidence

This is another rule we see broken often. Make sure your brand:

  • does not interpret and/or communicate the evidence inaccurately
    • recyclable is not the same as biodegradable; a product produced in a manufacturing plant with a low carbon footprint is not a low carbon footprint product if its shipping partners don’t comply with the same principles. 
    • consider your evidence carefully and make sure your statements reflect the evidence you hold, no more, no less. 
    • use only credible sources of evidence specific to your product’s ingredients and packaging.
  • does not communicate a statement without checking the evidence or facts properly
    • we often see brands claiming their packaging is biodegradable when all of its components may not be. If they checked their facts properly, they would have discovered this before making the claim – and then have the chance to ensure it lives up to its claims.  
    • make sure you investigate how sustainable, natural or biodegradable your ingredients really are, and hold the evidence in a product file. If you aren’t sure how to check this properly, learn it with us, or seek a consultant’s advice to check claims before they are made.


How a brand leader uses accuracy based on evidence to their advantage:

  • when you hold the evidence first, your claims will always be correct – it saves hours of desperate searching for evidence later if ever questioned by a regulator and prevents potential recalls.
  • credible evidence makes it easier to communicate your message using accurate terminology.
  • use % inputs or other specific identifiers to qualify your statements based on evidence – it makes your brand appear more knowledgeable than competitors who don’t.


3. Don’t omit or hide information to make your product sound greener than it is

Keeping certain information from a consumer is as bad as making a false claim. Choosing to not include particular claims about the non-green aspects of a product while highlighting the green aspects is another error many companies make.

For example, some companies may focus on the green ingredients in their product but hide the fact they use non-recyclable packaging. In this case, the company should make it clear their packaging is not recyclable, or better still, switch to recyclable packaging!

Another example is brands that highlight key ‘sustainable’ ingredients, but don’t mention the many non-sustainable ingredients they also use. Alternatively, the use of * to add explanatory footnotes about your claims or terminology could indicate your claims are dubious – if you need to use a * and fine print to explain the claim, then you should probably reconsider it. You may need a * to provide a footnote naming a source of evidence, and that is the only way they should be used. They should not be used to ‘qualify’ a statement that is made elsewhere in much larger font.

How a brand leader uses the temptation of omissions to improve their product:

  • if you are tempted to ‘hide’ key information, then you should fix it!
  • if you want to claim one product is 90% natural (or similar), then you should make the same sort of % natural claim across all products in your range. If you don’t want to admit the % natural because its not high, reformulate them all to achieve the claim – then promote it loud and proud. It increases the credibility of your brand to do so.  


4. Don’t make unmeaningful comparisons

Don’t pretend your product is more ‘green’ than another, or than it used to be, if the comparison is not fair or meaningful. Common examples of where brands go wrong include:

  • claiming their product is 50% more natural (or other %), when the original product had a very low natural % to begin with.
    • for example, if the original product was only 2% natural, it is misleading to say your product is 50% more natural, since the natural content is still incredibly low.
    • a consumer is likely to believe your product has a high % of natural inputs with a claim of ‘50% more natural’, so if it doesn’t, don’t make the claim!
  • ‘obvious’ claims are just as bad.
    • avoid obvious statements such as ‘using natural plant extracts’ – all plant extracts are considered natural.
  • avoid claims of unnatural ingredients that wouldn’t be used in that type of product anyway.
    • a common example is a claim like ‘does not include synthetic preservatives’ for a balm or oily serum – these types of products don’t need any sort of preservative, so claiming that it does not include something it wouldn’t need is misleading.
    • another common example is claiming your product is free from microbeads – these are prohibited in cosmetics anyway now, so this type of claim is redundant.


How a brand leader makes more meaningful comparisons:

  • use % inputs accurately, based on evidence you hold for each ingredient or packaging component.
  • highlight the key benefits for your product compared to a non-green version of the same product. For example, ‘uses a natural vitamin A alternative’ when describing a plant extract with the same activity as vitamin A.


How do companies use ‘greenwashing’ to their advantage?

Containing at least some green content is incredibly important to many brands, and so it should, as the future relies on us all! But the key message is to be truthful in your advertising, and if you can’t, then make changes to your products until you can.

There are some really easy ways to use green claims properly, and to your brands’ advantage:

  • be accurate with the % of natural and organic input, with or without certification, and state this clearly in your marketing.
  • investigate all components of packaging carefully and use the appropriate terminology.
  • make sure any ‘green’ statements comply with these key principles, based on credible evidence, and that you hold it specific to the ingredients and packaging you are using.
  • investigate and hold evidence, never assume.
  • clarify any blanket statements or avoid them and be specific instead!
  • consider the entire lifecycle of the product and how this is reflected in your claims and supported by your evidence.

Remember why you are claiming ‘green’ to begin with: it should be to provide your empassioned consumer with an amazing product that shows how it cares about its environmental impact, not just to sell a product. If you care about being green, you’d find you want to investigate your claims properly, ensure your products are as green as you say they are, and hold the evidence to be certain of your brands goals anyway.

Happy (green) formulating! 




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