By Julie Chen, Founder and CEO at Cheeky Panda

As consumers become more environmentally conscious, sustainability claims have become a powerful marketing tool. Carbon footprints, climate-friendly manufacturing, fossil-fuel-free production, and environmental superiority claims are now commonplace across many industries.

Unfortunately, sustainability is rarely as simple as the headlines suggest.

While environmental measurement has improved significantly over recent years, comparing brands based on a single carbon figure or environmental claim can often be misleading. In many cases, the differences are not driven by the product itself, but by what was measured, how it was measured, and what was left out. This is why both the UK's Competition and Markets Authority (CMA) and the Advertising Standards Authority (ASA) place significant emphasis on transparency, substantiation and avoiding misleading omissions in environmental marketing.

Carbon Footprints Are Not Universal Numbers

Many people assume a carbon footprint is an objective fact, similar to a product's weight or dimensions.

But in reality, every carbon assessment depends on choices regarding methodology, assumptions and system boundaries.

For example:

  • Which lifecycle stages are included? (For example, some assessments include product disposal (aka cradle to grave) and some include just up to delivery to the customer (aka cradle to gate)
  • Are emissions from disposal counted?
  • Are transport emissions included?
  • Which emissions databases are used?
  • How are shared manufacturing processes allocated?
  • Are recycling credits applied?

The answers to these questions can significantly impact the final result.

That’s why two organisations can analyse the same product using the same underlying data and still reach different carbon footprint figures because they apply different methodologies, interpretations or scopes.

That does not necessarily mean either assessment is wrong. It means carbon accounting involves judgement as well as measurement, and that makes comparisons difficult.

At Cheeky Panda, we have carried out independent lifecycle assessments using different methodologies for different purposes. Our LCD Consulting study assessed our bamboo toilet roll across a wide range of environmental indicators using a cradle-to-grave approach, while our more recent work with Carbon Footprint Ltd focuses on developing product-level lifecycle carbon footprint assessments across our range. This experience has reinforced our belief that understanding methodology, system boundaries and assumptions is essential before comparing environmental results between products or brands.

The Disposal Debate

One commonly overlooked area is end-of-life disposal.

Some assessments include:

  • Waste collection
  • Landfill emissions
  • Incineration impacts
  • Recycling outcomes

Others stop at the point of purchase or factory exit.

A study that includes disposal will often generate a different carbon footprint from one that excludes it.

This means two products with apparently comparable carbon claims may in fact be measuring entirely different things. Our own lifecycle assessments have generally included end-of-life disposal within the study boundary, but not all assessments adopt the same approach, making headline comparisons more difficult

Without understanding the assumptions behind the calculation, comparisons can easily become misleading.

The Hidden Problem: Omission

One of the most important principles within the CMA Green Claims Code is that businesses should not omit or hide material information that consumers need to understand a claim properly. Environmental claims should present a fair and accurate picture rather than selectively highlighting only the most favourable information.

This is where many sustainability claims become problematic, as a claim may be technically true in a narrow sense, while still creating a misleading overall impression.

The issue is not necessarily what is said. It is often what is left unsaid.

The "Fossil Oil Free Manufacturing" Example

Take a claim such as:

"Manufactured in a fossil oil free facility."

This may be factually correct if a factory operates using renewable electricity or avoids fossil-based fuels during a specific stage of production.

However, consumers rarely interpret such statements as applying to only one factory process.

Many will reasonably assume the claim reflects the environmental impact of the product as a whole.

Yet manufacturing is only one part of a product's lifecycle.

For example, a bamboo product sourced from China may involve:

  • Cultivation and harvesting activities
  • Raw material processing
  • Upstream transportation networks
  • Packaging production
  • International shipping
  • Distribution and warehousing

It would be highly unusual for every one of these stages to be entirely free from fossil fuel use. Therefore, while "fossil oil free manufacturing" may accurately describe a specific facility or process, it does not necessarily mean the entire supply chain is fossil-fuel-free. 

As a result, there can be concerns about whether consumers are being given the full picture. If a company highlights one favourable stage while remaining silent about the rest of the lifecycle, it risks creating an impression of environmental superiority that may not be justified.

Sustainability Is More Than Carbon

Another challenge is that carbon is only one measure of environmental impact.

A genuinely holistic sustainability assessment might also consider:

Some of these have been considered in previous lifecycle assessment work undertaken on Cheeky Panda products. For example, an assessment by LCD Consulting considered our bamboo toilet roll across a broad range of environmental indicators, including water use, land use, toxicity, resource depletion and biodiversity-related impacts. More recent product-level lifecycle carbon footprint assessments have focused specifically on greenhouse gas emissions. 

Because different assessments are designed for different purposes and do not always evaluate the same environmental indicators, broad environmental comparisons should be approached carefully, as a product with a lower carbon footprint may perform worse in other environmental categories. This makes broad claims such as "Most sustainable", "Greenest", "Best for the planet" or "Most environmentally friendly" especially difficult to substantiate.

The CMA states that comparative environmental claims must be fair and meaningful, while the ASA has repeatedly emphasised that broad environmental claims require robust evidence and must not mislead consumers through exaggeration or omission.

Why "Most Sustainable" Claims Can Be Greenwashing

When brands compare carbon figures calculated using different methodologies, different boundaries or different assumptions, consumers may be led to believe they are seeing a like-for-like comparison when in reality, they are not.

Similarly, when businesses highlight one positive environmental attribute while omitting less favourable parts of the lifecycle, they risk presenting an incomplete picture.

Claims of being:

  • "the most sustainable"
  • "the greenest"
  • "the lowest impact"

require evidence across the whole scope of the comparison.

Without transparent and comprehensive substantiation, such claims can cross into greenwashing territory because they imply a level of overall environmental superiority that may not be supported by the evidence available.

The Better Alternative: Transparency 

The most credible sustainability communication is not about claiming to be the best. It is about being transparent throughout.

When assessing environmental claims, important information can include:

  • What has been measured
  • What has not been measured
  • Which lifecycle stages are included
  • Which methodology was used
  • What limitations exist

At Cheeky Panda, we believe transparency means helping customers understand the evidence behind environmental claims rather than relying on headline figures alone. We encourage customers to review the lifecycle assessment information we make available to understand more about what has been assessed.

In conclusion

Carbon footprints are valuable tools for understanding and reducing environmental impact. However, they are not universal scorecards and they should not be treated as definitive measures of sustainability, and are not always comparable.

That’s because different methodologies can produce different results. Different lifecycle boundaries can generate different figures. Different assumptions can change the outcome. And perhaps most importantly, selective disclosure and omission can create an impression that does not reflect the full environmental picture.

To get the full picture, consumers should not simply ask, "What does the claim say?", but also "What does it leave out?" Because in sustainability marketing, what is omitted can sometimes matter just as much as what is measured.