Greenwashing is complex and we need a balanced approach to regulating it

Bill Whitelaw

I’ve been thinking a lot about the concept of greenwashing.

Greenwashing is based on the premise that colours are highly emotive and polarizing. The “greens” at each end of the perspective spectrum are vastly different, with a multitude of shades in between, especially in the oil and gas sector.

However, we rarely probe how these shades of greenwashing affect people’s perceptions of climate change and the environment.

“Green” is not absolute – what is lime green to one person may be emerald green to another. Despite what regulators and activists might believe, there is no universally accepted “green absolute.”

My recent thoughts have been shaped by changes to Canada’s Competition Act, designed to tighten greenwashing regulations and ensure market competitiveness. Although not specific to oil and gas, the sector serves as a good example of how people perceive greenwashing as a socio-political construct.

Greenwashing regulations need to be based on fairness and not fear of persecution
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How people think of these varying shades of green will play a crucial role in the evolution of a decarbonizing energy sector. This shift will occur as the public becomes more involved in decisions regarding the intersection of energy, environmental security, and stability.

I’ve been incorporating this “psychology of shades” into a three-element framework designed to anticipate and monitor changes in the energy system, as well as to contribute constructively to the challenging decisions that will increasingly impact everyday life.

This framework is still in development, but here are its conceptual foundations:

Permissions to Produce

The concept of a social license to operate is dead. “Permissions to Produce” offers a different analytical approach to two-way engagement, relying on a more informed public and an energy sector far more attuned to consultation. In the context of greenwashing, this approach helps distinguish between spurious and credible claims and makes the energy industry more aware of societal boundaries for progress. Consequently, public permissions, both implicit and explicit, based on context, will become crucial for the sector’s evolution and change.

Conditions of Combustion

The industry (for the most part) is primarily focused on reducing emissions through various means. However, this isn’t always reflected in the headlines. “Conditions of Combustion” offers an analytical set of tools to assess how these efforts are perceived by the public and how they affect consumer behaviour. The core of this approach is a set of measurement methodologies that are understandable to both society and energy producers. This approach allows “scorecards” to track progress over time, showing significant improvements in measurable reductions. In other words, when emissions reduction claims are made, consumers should be able to understand and evaluate these claims because they are familiar with the accepted methodologies.

Conundrums of Consumption

This framework provides ways to analyze how ordinary Canadians perceive their role as consumers within the energy systems they depend on and what they find acceptable regarding “green” claims. “Conundrums of Consumption” tracks and explores changing attitudes across generations toward energy use and how individuals and communities adapt to changes. It focuses on understanding how people balance lifestyle choices with environmental imperatives while navigating critical decisions about energy security, supply stability, and environmental impact.

These three sub-frameworks do not operate independently. They are designed to inform and complement each other, operating within the “messy middle” of Canadian society where most people live, work, and play – and where there is the most potential for progressive critical mass creation.

My framework is part of a two-part submission I plan to make to the Competition Bureau’s call for public input. I hope to answer as many of the regulators’ questions as possible. And I’m taking the Bureau up on its offer to post all submissions publicly on its website to gather input and feedback.

I hope to provide regulators with a clearer understanding of the sector’s progress in terms of its environmental impact. I will suggest that a more nuanced, less heavy-handed approach to greenwashing is needed while still enhancing the public’s right to a deception-free competitive marketplace.

The second part of my submission will address the specific questions the Bureau posed in the public consultation on the new greenwashing provisions of the Competition Act.

Canada has a great opportunity to create a balanced regulatory system that holds true greenwashing accountable while transparently measuring progress across all industries. This system should allow companies to innovate without fear of persecution, understanding that being “green” is context-dependent and contingent on circumstances.

Bill Whitelaw is a director and advisor to many industry boards, including the Canadian Society for Evolving Energy, which he chairs. He speaks and comments frequently on social licence, innovation and technology, and energy supply networks.

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