C
Content
What companies say and how clearly they say it. Evaluates the specificity, accuracy and clarity of environmental claims — whether language is concrete and substantiated or vague and generic.
Methodology
How Mossy works — the CARE model
Mossy is built on the CARE model, a peer-reviewed scientific framework developed by Dr Sara Rego through doctoral research at the Communication and Society Research Centre (CECS), Universidade do Minho (Rêgo, S., 2024. Comunicação para a Sustentabilidade: a influência do consumo consciente na comunicação corporativa em tempo Covid-19. PhD thesis, Universidade do Minho).
The model evaluates sustainability communications across four dimensions, equally weighted, assessing 46 criteria in total. The specific criteria are proprietary and derived from peer-reviewed research.
The four dimensions
A
Aim
Whether sustainability sits in the company's purpose, mission and values — or is treated as a marketing add-on. Evaluates alignment between stated commitments and organisational strategy.
R
Reporting
Targets, governance and transparent disclosure. Evaluates whether companies publish measurable targets, third-party verified data, and clear governance structures around sustainability.
E
Engagement
Real two-way dialogue with stakeholders — not one-way broadcasting. Evaluates the existence of genuine participation mechanisms, feedback channels, and stakeholder-specific communication.
Risk scoring
Each scan produces a risk score from 0 to 100:
0–33 · Low Risk
claims are specific, substantiated and defensible under applicable frameworks
34–66 · Medium Risk
some claims lack specificity or evidence
67–100 · High Risk
claims are vague, unsubstantiated or potentially misleading under applicable regulation
Higher scores indicate greater greenwashing risk. This is a risk indicator, not a legal assessment.
The 9 regulatory frameworks
Mossy evaluates claims against 9 frameworks simultaneously:
Mossy evaluates content against all 9 frameworks simultaneously — distinguishing binding rules, reporting standards, voluntary standards, guidance and proposed legislation.
- ISO 14021 — Self-declared environmental claims (International)
The standard governing how companies make environmental assertions about products and services.
- FTC Green Guides — US guidance on environmental marketing claims (US)
Federal Trade Commission guidance on what constitutes misleading environmental marketing.
- UK Green Claims Code — CMA guidance on green claims (UK)
Competition and Markets Authority principles for making credible environmental claims.
- CSRD / ESRS — Corporate Sustainability Reporting Directive (EU)
Mandatory sustainability reporting for EU companies with more than 1,000 employees and more than €450 million net annual turnover, under Directive (EU) 2026/470 (Omnibus), in force 18 March 2026. Applies from financial years beginning on or after 1 January 2027. Listed SMEs and companies below these thresholds are exempt from mandatory reporting but may choose to report voluntarily.
- EU Directive 2024/825 — ECGT (EU)
Empowering Consumers for the Green Transition — prohibits unsubstantiated generic environmental claims from 27 September 2026.
- CSDDD — Corporate Sustainability Due Diligence Directive (EU)
Due diligence obligations for very large companies regarding environmental and human rights impacts across their value chain. Under the Omnibus Directive (EU) 2026/470, in force 18 March 2026, mandatory scope is limited to EU companies with more than 5,000 employees and more than €1.5 billion net worldwide turnover, and non-EU companies with more than €1.5 billion EU turnover, applying from 26 July 2029. Companies below these thresholds are out of scope but may face value-chain expectations.
- EU Green Claims Directive (proposed)
Proposed EU directive on substantiation and communication of environmental claims. Currently under political review — not yet in force but may be revived. Reflects best practice for future compliance.
- Australian Consumer Law — ACCC (AU)
Australian Competition and Consumer Commission guidelines on environmental claims — one of the most actively enforced greenwashing frameworks globally.
- Dutch ACM Sustainability Claims Guidelines (NL)
Practical enforcement-oriented guidelines from the Dutch Authority for Consumers and Markets. One of the most actively enforced green claims frameworks in the EU, with a focus on clarity, substantiation, and the overall impression created by environmental marketing.
Evidence standards
In addition to the 9 regulatory frameworks, Mossy references the following internationally recognised evidence standards when evaluating specific types of claims:
GHG Protocol
The global standard for measuring and reporting greenhouse gas emissions. Referenced when evaluating carbon, Scope 1/2/3, net zero, and climate-related claims. Claims using emissions language without reference to GHG Protocol methodology or equivalent are flagged.
ISO 14040 / ISO 14044 — Lifecycle Assessment
The international standards for lifecycle assessment methodology. Referenced when evaluating comparative environmental claims such as “lower impact,” “reduced footprint,” or “better for the planet.” Claims implying lifecycle benefits without a lifecycle assessment are flagged.
ISO 14067 — Product Carbon Footprint
The standard for measuring and communicating product-level carbon footprints. Referenced when evaluating per-product carbon claims. Claims making per-product carbon assertions without ISO 14067 or equivalent certification are flagged.
SBTi Corporate Net-Zero Standard
The benchmark for science-based and 1.5°C-aligned net zero commitments. Referenced when evaluating corporate net zero and science-based target claims. Claims using “net zero,” “science-based,” or “1.5°C aligned” without SBTi or equivalent independent verification are flagged.
AI and accuracy
All Mossy analysis is generated by Google Gemini 2.5 Flash via the Lovable AI Gateway. Results are AI-generated and should be treated as risk indicators, not legal assessments. Mossy uses the CARE model methodology to guide AI analysis but results should be reviewed by a qualified professional before acting on them.
In compliance with EU AI Act Article 50, all AI-generated outputs are clearly labelled as such.
Citation
Rêgo, S. (2024). Comunicação para a Sustentabilidade: a influência do consumo consciente na comunicação corporativa em tempo Covid-19. PhD thesis, Universidade do Minho. Available at: repositorium.uminho.pt