Five tips to avoid “greenwashing” when marketing paper products

Submitted by: Phil Riebel 03/07/2015

(…and why major corporations are now removing “go green – go paperless” claims)

By Phil Riebel, President, Two Sides North America

“Greenwashing” is now a term most of us are familiar with.  It means “the practice of making an unsubstantiated or misleading claim about the environmental benefits of a product, service or technology.” Terrachoice[i] found that over 95% of “greener” products commit one or more of the seven “Sins of Greenwashing,” so it’s a major problem in the marketplace.  Paper products in particular seem to suffer from many unsubstantiated and vague claims, especially when it comes to corporations trying to promote electronic services over paper-based communications.

The bottom line is that corporate marketers need to follow certain specific guidelines for environmental marketing, such as those published by the U.S. Federal Trade Commission[ii], and in Canada by the Competition Bureau of Canada[iii].  If they don’t, their company could face corrective action by the FTC[iv].  The International Standardization Organization (ISO) also has a series of standards on environmental declarations (ISO 14020) and has classified environmental claims into three categories – Type I, Type II and Type III.

Tip #1:  Aim for rigor and assurance of claims (ISO Type I claims)

Type I eco-labels (ISO 14024:1999)[v] are independently verified by a third party and are typically based on the environmental impacts of a product or service (environmental performance according to predefined criteria and/or a set of environmental attributes).  Familiar eco-labels with Type I features used in the paper industry include the following:

  • Labels from forest certification organizations such as the Sustainable Forestry Initiative® (SFI®)[vi], the Forest Stewardship Council™ (FSC®)[vii] and the Program for the Endorsement of Forest Certification (PEFC®)[viii] which verify that paper products are manufactured using fiber from responsibly managed forests.
  • The Ecologo®[ix] and EU Eco-label®[x] which evaluate several criteria over the life-cycle of paper products, including performance of pulp and paper mills and greenhouse gas emissions.
  • Green-e[xi] which certifies companies for the use of renewable energy.

For more, see the Global Ecolabeling Network at

Tip #2: Self-declared claims need to be factual, substantiated and not misleading (ISO Type II claims)

Type II self-declared environmental claims (ISO 14021:1999)[xii] are typically made by companies to promote the environmental aspects of a product or service and can be in the form of a declaration, a logo, an advertisement or other corporate marketing materials.  The common claims that electronically delivered documents are “greener” than documents printed on paper falls into this category, as well as claims that indicate a product is recyclable or contains recycled content.[xiii] 

These claims are usually based on a single environmental attribute  without taking into account the environmental impact of a product’s entire life cycle, and without independent verification or certification by a third party.  However, the guidelines require the following:

  • Environmental claims shall be accurate, verifiable, relevant and not misleading.
  • Methodology must be able to produce results that are accurate and reproducible.
  • Information concerning the procedure and methodology shall be available.
  • Require competent and reliable scientific evidence consisting of tests, analyses, research, or studies that have been conducted and evaluated in an objective manner by qualified persons and are generally accepted in the profession to yield accurate and reliable results (based on standards generally accepted in the relevant scientific fields).

Guidelines also specify that: “claims shall not be vague, non-specific, and broadly imply that a product is environmentally beneficial (environmentally friendly, green).   Such claims are difficult to substantiate, if not impossible.” Likewise, the ISO standard specifically states that the use of natural objects (trees, the globe, leaves) must not be used unless there is a direct and verifiable link between the object and the benefit claimed.

In other words, stick to the facts and do not overstate or generalize environmental benefits - a common mistake of those accused of ‘greenwashing’.  Examples of over-stating environmental claims are sometimes seen when companies promote the use of recycled or “tree-free” fiber as a raw material for papermaking.  According to the US FTC, claims such as “green, made with recycled content” may be deceptive if the environmental costs of using recycled content outweigh the environmental benefits of using it. 

Tip #3: Measure and report based on key performance indicators (ISO Type III claims)

Type III environmental impact labels (ISO 14025:2006)[xiv] are used in about 10 countries and require exhaustive life cycle data sheets called environmental product declarations (EPD)[xv].   Environmental parameters are fixed by a qualified third party.  Companies then compile and report environmental information and these data are independently verified. The environmental impacts are expressed in a way that makes it very easy to compare different products and sets of parameters. 

The following tools include EPDs and scorecards with EPD features commonly used for paper products:

  • Paper Profile[xvi]
  • Environmental Paper Assessment Tool (EPAT)[xvii]
  • PREPS - The Publishers’ Database for Responsible Environmental Paper Sourcing[xviii]
  • WWF Paper Scorecard[xix]

Tip #4: Use sustainability reports to tell your full story

Many companies tell their full environmental story via an annual sustainability (or environmental) report.[xx]  Guidelines issued by the Global Reporting Initiative (GRI)[xxi] lay out recommendations to ensure credibility and transparency.  Reports can also be audited to confirm that they meet GRI standards.

My suggestion is that companies develop a user-friendly version of their environmental report and make it available to consumers via their website and in print.

Tip #5: Don’t forget public opinion and who your customers are!

In the U.S. alone, 8.4 million jobs rely on the paper, print and mail value chain and this is equivalent to annual revenues of $1.3 trillion or 6% of total U.S. jobs[xxii].  In Canada, there are over 800,000 mail-related jobs, almost 5% of all jobs in the country. Revenues from this sector are estimated at $88 billion, or 5% of total GDP in Canada.[xxiii]

Many of these people work in pulp and paper mills, forestry operations, post offices, printing plants and many businesses that rely on the graphic communications industry.  They are also all customers of corporations providing essential services (i.e. banking, telecommunications, insurance, utilities, insurance, automotive, etc…).  Therefore, corporate marketers may want to ask themselves:

  • How are claims such as “go green, go paperless, save trees” perceived by customers who work in the graphic communications industry?
  • Are these claims affecting their income and their livelihood in a negative way?

A public opinion poll conducted in the U.S. by Two Sides[xxiv] shows the following results:

  • 72% agree that print & paper can be an environmentally sustainable way to communicate (if produced & used responsibly);
  • 50% do not believe, feel misled by or question the validity of claims like “Save Trees”;
  • 34% are ‘home printers’ of e-statements received electronically;
  • Over 84% agree that e-statements are promoted to save costs.

These results are also supported by consumer studies done by the US Postal Service[xxv], Royal Mail[xxvi], and EMA[xxvii] which clearly show that most consumers want to retain a paper option and they see paper as an important part of their lives.

In the end, all products and services have complex life cycles with positive and negative impacts.  The key is to continually improve responsible procurement, production and use of all products & services, whether it’s paper or electronic, and follow best practices for environmental marketing to avoid greenwashing and upsetting customers.

Additional resources:

[i] Terrachoice, 2010

[ii] US FTC Green Guides

[iii] Competition Bureau of Canada, 2008

[iv] US FTC Press Release

[v] ISO 14024 - Environmental labels and declarations - Type I environmental labelling -Principles and procedures




[ix] Ecologo

[x] EU Eco-label

[xi] Green-e

[xii] ISO 14021 - Environmental labels and declarations -- Self-declared environmental claims

[xiii] AF&PA, Paper Recycling Symbol Guidelines & Environmental Marketing Claims

[xiv] ISO 14025 - Environmental labels and declarations - Type III environmental declarations - Principles and procedures

[xv] Descriptions of EPD Programs - EPA ,UL, ASTM



[xviii] PREPS

[xix] WWF Paper Scorecard

[xx] Two sides reference sheets on responsible production and use of print and paper

[xxi] Global Reporting Initiative

[xxii] EMA, 2013

[xxiii] EMA and Robustion Technologies Inc., 2014

[xxiv] Two Sides Consumer Study, 2013

[xxv] US Postal Service, 2015. Will the Check Be in the Mail? An Examination of Paper and Electronic Transactional Mail

[xxvi] Royal Mail – Keep Me Posted

[xxvii] EMA / Infotrends National Consumer Study, 2013