When it comes to sustainability communications, what you can say and to whom has become the hot topic of the year thanks to a tightening of consumer protection laws. But the rules are so far unclear how is the outdoor industry responding?

The European Union is expected to vote into law a broad package early 2023 known as the EU Initiative on Substantiating Green Claims. But while its goal of eliminating greenwashing and consumer confusion is welcomed by many in the outdoor industry, exactly how the legislation will be implemented in practice has created a great deal of confusion on its own. With sustainability communications campaigns already in motion and products being designed today that will likely be sold once this legislation enters into force, how is the Outdoor industry dealing with this uncertainty? Suston reaches out to four industry actors – the brands Rab and Bergans, the online retailer The Fair Cottage, and communications experts GreenroomVoice – to find out.

As we await to see what final form EU Substantiating Green Claims legislation takes and whether or not it is enacted in 2023, do you think communicating sustainability initiatives is worth the risk?

GreenroomVoice: Yes, we would strongly suggest to continue communicating sustainability, but to involve experts on sustainability in communication. Many claims are technically wrong, not because the brands intentionally greenwash, but because communication experts are (most of the time) not sustainability experts, and the other way around to be fair. This lack of knowledge can at best lead to dull communication or at worst false claims.

Bergans: We’re happy to see this is finally on the agenda, but now there’s a reemergence of uncertainty where many are afraid of being called out by NGOs or regulators if they stick their necks out. Staying quiet might seem like the safe choice. In spite of this, I think that it’s really important to keep communicating our sustainability efforts. Because as businesses communicate, they push each other forward in friendly competition and also increase the threshold of what consumers can expect of brands and their products.

Rab: We continue to see increased consumer demand for detailed information about how products are made and what environmental impact they have. So yes, we must continue to inform our consumers who are entitled to know how we are working with sustainability. As a company, we have embarked on an open and transparent approach as part of our journey to reach Net Zero by 2030. Therefore, we are committed to meeting these increased expectations, providing guidance and supporting retailers with their communications.

The Fair Cottage: We believe that sustainability needs to be communicated not necessarily at the forefront of branding and marketing strategies, but at the core of the whole business structure. Understanding sustainability holistically is crucial for such integration. I would say, brands and retailers have to put at customer’s disposal more educational information rather than just using insights to make claims. Developing more and better knowledge is a prerequisite to creating an understanding backbone to the entire industry.

What can be done to address green claims communications risks proactively?

GreenroomVoice: The purpose of our work at GreenroomVoice is to communicate with an objective and journalistic approach, which is customized to the kind (i.e. Supplier, Brand, etc.) and size of business. For us, it’s always the context in which the action is taking place that matters. We look at the brand’s situation and the daily business operations in all the most relevant categories in line with standard methodologies. The result is a profile as a solid base for communication. For the new profiles 2023, on which we are working right now, we have joined forces with the public affairs agency Ohana in Brussels. Their experts will make sure to raise flags when they come upon areas of action within the profiles that are subject to upcoming legislation. This way, our members will be informed with a good head start.

Bergans: The key is, and has always been, to be clear and have the documentation to back it up. Of course, this might be seen as boring and the marketing department will have their work cut out for them. But it really does most justice to the consumer and keeps you out of trouble. On the other hand, this is not just about our sustainability or marketing team. It also involves our athletes, influencers, retail staff, web content producers – everyone who communicates externally on Bergans’ behalf. Here, we’ve been very intentional about regularly educating our entire organization on what it means to communicate sustainability responsibly.

Rab: Sustainability and sustainability communications are highly complex issues, as they involve a multitude of factors at different levels. We need to grasp the complexity and ensure that we, as well as retailers, are armed with the right communication tools to meet with consumers’ expectations. Therefore, our strategy with CSR communications has been and continues to be transparency. Our Sustainability Report, as well as our Social Report, provide evidence of the steps we’re taking and external partners such as South Pole and Fair Wear Foundation ensure our data is accurate. We believe in being bold and proactive in our comms, but at the same time recognize that we’re all on a learning process that we can best tackle together as an industry.

The Fair Cottage: I think that it’s important to understand that consumers engage more with brands than with claims themselves. When speaking about branding, this is always the most engaging part of it:
It’s about the story, the roots, the spirit, the values! In many spaces, people have begun to normalize green claims and they look for something beyond it, something that makes brands unique while also being closer to their values. Legislation will hopefully help people to both recognize those brands making vague marketing claims and to consider integrating more sustainable purchasing decisions.

What are your concerns with the legislation as currently proposed? What do you see as its benefits and potential pitfalls?

GreenroomVoice: We welcome the EU’s proposals to substantiate green claims, as misleading information is in our eyes the main obstacle to engage the consumer in a long-term relationship with a brand. Once a consumer has been disappointed, it is very hard to regain trust. If it also helps create clarity in the jungle of certifications, this is a good thing. Of course, this will probably also be its biggest challenge. Using just one label that covers everything for comparability etc. will also be based on LCA averages. This will not always correctly reflect the actual impact of the product, especially when we speak about innovations. The difficulty here will also be to agree on a common scope on LCA measurements in order to make different materials truly comparable with each other. That being said, we need narratives that support science. We are in a climate and biodiversity emergency, and we need all hands on deck!

Bergans: As sustainability has gone from a “nice to have” to a “need to have,” sustainability claims have become widespread and some people go overboard. We’ve of course been bothered by a minority that take this a step further by bragging when there’s nothing to brag about. For this reason, I welcome legislation that levels the playing field to inform consumers and reward those putting in the effort.

But how that will all play out is an entirely different issue. The current proposal mentions promoting certain certifications like the EU Eco Label, and not recognizing others. What if you’ve based all your work on a standard that is not included? Another thing is that here at Bergans, “Built to Last” is one of our sustainability pillars. But how do you support durability claims with data? If you can’t market the USP, and it costs more, then there’s little incentive. There are countless such trade-offs that industry experts have spent years struggling to account for, and now EU legislators are going to try to sort this out? We’ll just have to see. My hope is that at the very least, the legislation will be understandable and workable, and ultimately that good guidance will be the result for both business and consumers.

Rab: We feel that the Green Claims legislation will help clarify sustainability messaging, and avoid consumers being misled by ambiguous or inaccurate information. We strongly advocate for an aligned industry-wide dialogue with the potential for us all to learn, adjust and improve our approach. Let’s take one step after the other, but let’s keep moving forward!

The Fair Cottage: I am concerned about how high the threshold for small brands will be. Going through bureaucracy, certification processes, third-party audits and of course paying all the fees is already a hassle for them. I really hope the legislation brings more accessibility and clarity rather than complications. That said, I think communications have become tricky to understand and have led to misinformation, vague claims and complexity. I believe that legislation is needed to tackle this problem and regulate how information should be communicated more transparently, aiming to inform and educate.



In 2019, as part of the EU Green Deal, the EU Commission announced an initiative that would aim to reduce the risk of false or misleading green claims, stating that “Companies making ‘green claims’ should substantiate these against a standard methodology to assess their impact on the environment.” This was further specified under the 2020 Circular Economy Action Plan, where the Commission announced it would prepare a legislation proposal whereby green claims would need to be substantiated using the EU Product and Organisation Footprint (PEF and PEO) methods developed by the Commission’s own Joint Research Centre.

Following a public consultation period in 2020, the proposal has since been postponed several times. At time of writing, it is expected to be a part of the Circular Economy Package II slated for the end of November 2022.



Jonathan Eidse
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