Advertisers, lobby groups and industry bodies have been busy poring over the government's draft guidance on green claims for marketers looking to build the environmental agenda into their campaigns.
The guidance, which was released at the end of last month for consultation, has been a long time in development. It is well over a year since the Department for Environment, Food and Rural Affairs (Defra) kicked off a round of meetings to decide the code's content.
The review of the guidelines, last revised in 2003, is long overdue. Climate change has climbed up the political agenda over the past seven years, triggering an upsurge in green marketing, which has become increasingly sophisticated.
It is important that marketers get to grips with this. Although the guidance is voluntary, it is backed by legislation; all environmental claims about consumer products are subject to the fairness tests in the Consumer Protection from Unfair Trading Regulations 2008.
Additionally, while the Committee for Advertising Practice and its broadcast equivalent, BCAP, have their own environmental section, the codes advise that advertisers take the guidance into account, so it would be referred to in any Advertising Standards Authority adjudications.
More detailed blueprint
A glance through the updated document reveals that it is more thorough than the previous set of guidelines, rather than stricter.
There is greater detail and clarity about how to make a 'good environmental claim' and the wider context on why this is important is also a new theme. As a consequence, it goes beyond the narrow window of claims to exploring emerging concepts such as 'choice-editing' (see expert comment).
In this way, it provides more of a blueprint for companies by highlighting the broader range of activities, beyond marketing, that they can employ to help consumers reach more environmentally sustainable purchasing decisions.
It appears that lobbying by the marketing industry may have been more successful than that from the environmental contingent.
Becky Willan, co-founder of sustainability specialist Given London, who took part in discussions, welcomes the result. 'There did seem to be a divide between NGOs, saying that the claims should be regulated, and people like me, saying that we need to encourage brands to make claims and engage in the agenda,' she says.
While the latest version, like its precursor, warns about the use of terms such as 'green', 'environmentally friendly' and 'eco', it also examines the risks that are associated with doing so, which Willan says is a more 'helpful and pragmatic' approach.
However, Blake Ludwig, managing director of environmental pressure group We Are Futureproof, condemns the guidance for 'failing to make any strong statements'. He also slams the suggestion that brands should use third-party verification as 'vague'. 'What third party is acceptable?,' he asks. 'This really needs to be clarified.'
Ludwig, whose group is mainly concerned with the automotive industry, believes the section on the use of imagery needs to be stronger, as car ads are usually shot in the countryside.
'People look at car ads and they notice the imagery first, before they see CO2 information,' he argues.
Defra acknowledges a lack of awareness and use of its green claims guidelines among marketers. Once the consultation is over, it will look to run workshops in partnership with the industry to raise the profile and understanding of the guidance.
Diane Verde Nieto, founder of sustainability communications consultancy Clownfish, says the guidelines would benefit from being built fully into the CAP and BCAP codes. 'We need to think about how we can integrate the guidelines into the codes to normalise sustainability,' she adds.
The consultation closes in just over a month's time. Defra has not ruled out monitoring its use by brands, so marketers looking to base strategies on the environment should take the opportunity to make their voices heard.
EXPERT COMMENT - ENERGY SAVING TRUST: CHOICE-EDITING
- Antoinette de la Motta, Category marketing manager, Energy Saving Trust
Choice-editing - the conscious removal of inefficient products from a market - benefits the supply chain, consumer and country. Reluctance to implement it usually surrounds concern about the limitation of consumer choice. However, consumers expect retailers to edit product ranges for them, as long as it doesn't affect choice of features or price. Many are shocked that inefficient products are even available.
We encourage businesses to choice-edit and maximise efficiency of marketed goods. As such, we have embarked on the first Voluntary Retailer Initiative. Aimed at choice-editing TV ranges, the result will ensure that consumers can select only energy-efficient TVs when they buy a new model.
The objective is to engage the retail supply chain to improve product efficiency ahead of EU legislation, contributing to UK carbon-saving targets and saving consumers money on their energy bills.
More than 50% of UK TV retailers have signed up so far.
The commitment will raise brand profile with stakeholders and consumer awareness of the brands' environmental commitment and educate staff on the benefits of energy-efficient products. In short, it is a great PR opportunity that also has a positive environmental impact.