Green or Greenwashing: Who Gets to Decide?

Last May, H&M introduced new scorecards designed to grade and market the sustainability credentials of materials used in select garments to shoppers.

A little like nutrition labels that detail the fat, sugar and protein content in foods, the fast fashion giant’s scorecards break down how fabrics perform in areas like global warming, fossil fuel use and water pollution. But there’s one major difference: nutritional labels on food products are strictly regulated by government bodies; sustainable fashion isn’t.

That’s becoming more of a problem as sustainable fashion becomes big business.

Consumers, especially young ones, consistently rank sustainability as an important factor in purchasing decisions, even if price and cool factor remain bigger drivers. In response, brands have flooded the market with eco-claims and Earth Day capsules, but an absence of regulation has enabled a marketing free-for-all with plenty of space for greenwashing.

Sustainability labels like H&M’s are part of a trend in marketing towards greater transparency and accountability. In early 2020, Allbirds introduced a carbon calorie count for its products; last year Zalando stocked more than 140,000 products in its sustainable assortment; and brands including Moncler, Burberry and Chloé have committed to roll out digital IDs containing sustainability information.

But the labels currently used by retailers lack common standards and may cover a broad and varied set of criteria, from greenhouse gas emissions to living wages.

Now, growing scrutiny from regulators is stoking an increasingly urgent debate over what “sustainable fashion” really means and how it should be measured.

The issue is coming to a head in Europe, where policymakers are set to lay out rules as soon as July governing how brands will be required to back up environmental claims.

Industry efforts to establish common standards have already embroiled brands, suppliers and trade groups in a battle for influence over how guidelines are framed. Meanwhile, industry watchdogs are campaigning to ensure issues like lack of independence, transparency and rigour that they say plague business-led standards don’t become further entrenched.

Growing scrutiny from regulators is stoking an increasingly urgent debate over what “sustainable fashion” really means and how it should be measured.

The stakes are high: bad labelling fails consumers, erodes trust in brands and puts efforts to reduce the industry’s impact at risk with misinformation that hampers attempts to drive real change. Rules governing the way claims are presented and the underlying metrics used to substantiate them also stand to create commercial winners and losers, with materials, products and brands that perform better gaining a positive green glow with consumers and those that underperform at risk of losing market share.

Ultimately, the debate comes down to a key question: what’s green and what’s greenwashing — and who gets to decide?

The Road to Regulation

For more than a decade, fashion’s efforts to create a single approach to measure sustainability have been largely driven by the Sustainable Apparel Coalition, an industry alliance established in 2010 thanks to the efforts of Patagonia founder Yvon Chouinard and Walmart’s chief merchandising officer at the time, John Fleming.

Back then, it was rare for brands in fashion’s hyper-competitive market to collaborate or share information about their supply chains, but the pitch from Chouinard and Fleming was clear: the industry needed a standardised way to measure its social and environmental impact to get ahead of regulation, lower costs and barriers to change and ultimately reap the benefits through clear communication with consumers.

In the intervening years, that rationale has changed little, but its value to brands and retailers has become clearer as interest in sustainability has grown amongst consumers, investors and regulators alike.

Today, the SAC is one of fashion’s most powerful sustainability-focused trade groups, with more than 250 members, including the industry’s biggest brands and retailers, as well as manufacturers, academics and environmental groups. Its suite of tools, known as the Higg Index, is widely used throughout the sector. The scorecards H&M introduced last year, for example, are powered by the Higg materials module. The organisation is aiming to enable brands to plug in data about social and manufacturing impact to such labels too, with a goal for all its member brands, retailers and supplier to offer public-facing sustainability labels by 2025.

Critics say the tool is not fit for purpose and should not be used as a basis for making credible sustainability claims in marketing messages.

“The gap between the data that we have and what the companies and the public needs to know just keeps growing,” said environmental scientist Linda Greer, who stepped down from the board of the SAC last year in frustration over a lack of focus on improving the quality of information available. “There are critical gaps and inaccuracies.”

Natural and animal fibre producers like the wool and leather industries have also objected to the way materials are scored in the Higg. Last year, a group representing the silk industry wrote to the US Federal Trade Commission and the state attorney general in California claiming the Higg misrepresents the material’s impact.

The SAC said it has not received any inquiry from either the FTC or California’s attorney general. Its tools use a standard methodology to measure environmental impact and are based on the most up-to-date and robust data available, it said.

Now, these same tensions are playing out at a regulatory level, where the SAC is coordinating efforts to establish a tool intended to underpin green claims for clothing and footwear sold across Europe.

Measuring What Matters

For much of the last three years, Baptiste Carrière-Pradal has navigated the heart of the debate as chair of the multi-stakeholder group responsible for hashing out how the policy standard will work. It’s part of a broader European push to regulate green claims across a variety of products and represents one of the most mature regulatory efforts to establish a standardised way to measure fashion’s environmental impact.

For Carrière-Pradal, part of the challenge is that the tool he’s working to create, known as the Product Environmental Footprint (PEF), was not designed to measure sustainability defined broadly. Instead, the EU framework focuses on 16 specific areas of environmental impact. It doesn’t take into account the conditions in which clothes were made, how workers were paid or other social impacts. It doesn’t look at renewability or biodegradability. And for now it doesn’t include a metric for biodiversity or consider microplastic pollution.

“If no one was calling it a sustainability tool, it would be less of a problem,” said Carrière-Pradal. “It’s not the alpha and omega of sustainability.”

The debate comes down to a key question: what’s green and what’s greenwashing — and who gets to decide?

The challenge is that measuring fashion’s impact is particularly complex and the consumer market the industry serves is used to simple messaging. While exactly how the PEF will be deployed is still part of policy negotiations, it’s widely expected that it will be used to help back up consumer-facing product labels. In that context, the limits of what it measures risk misleading consumers, critics argue.

Last October, a coalition of brands, advocacy organisations and natural fibre trade groups — who worry the methodology used may mean their materials fare badly under the new rules — launched a campaign pushing to widen the scope to take into account metrics including social impact, microplastics and how long a product remains in use once it’s sold.

“I don’t think you have to be a marketing expert to know that products with a whiff of sustainability about them will appeal to consumers,” said Emily Macintosh, policy officer for textiles at the European Environmental Bureau, a network of civil society organisations that has observer status on the PEF committee.

Bad Data, Bad Outcomes

In 2018, Veronica Bates Kassatly was living in Berlin, trying to build a sustainable fashion brand. It was a dizzying process, trying to navigate a maze of claims, counterclaims, industry-backed certifications and self-regulated standards. For Bates Kassatly, whose background included time as a financial analyst at the World Bank, there appeared to be alarmingly little basis for many of the impact assessments available.

“I kept reading LCAs and finding they don’t say what people claim,” Bates Kassatly said, referring to Life Cycle Assessments commonly used to measure environmental impact. She’s spent the last four years researching the data the industry uses to support its sustainability claims, co-authoring a two-part report critiquing the current frameworks in play. The gaps, she said, are so significant that there just isn’t robust enough information to support tools like the PEF.

“We can’t possibly have people putting these kinds of made-up numbers into legislation,” said Bates Kassatly. “It’s misleading and unsubstantiated; it really is incredibly important and time is of the essence.”

The European Commission is in the process of reviewing data that could be used to support the PEF and exactly what the tool will look like won’t be finalised until 2024. But the scope of its influence is likely to become clearer in the coming months. In July, the European Commission is due to publish a proposal on how brands will be required to back up green claims, potentially laying the groundwork for the tool to become the backbone for how environmental impact is communicated to consumers. Such a move would put the PEF in pole position to become a template for global standards.

But even if underpinned with a solid tool, efforts to establish environmental labels risk simply enabling more consumption, which, for many at the heart of fashion’s sustainability debate, is the underlying issue no matter how green garments become.

“We’re wary of too much emphasis on trying to measure the environmental performance of products without any real attempt to reduce the numbers of those products in the first place,” said Macintosh. “We can’t label our way out of overproduction.”