Environmental management certification and environmental performance: Greening or greenwashing?

Abstract

This article analyzes the contribution of certifiable environmental management standards—such as ISO 14001 and the Eco‐Management and Audit Scheme (EMAS)—to corporate environmental performance. Based on a content analysis of 414 third‐party‐verified environmental statements from EMAS‐registered Spanish organizations, which included information for around 6,700 detailed indicators, a weak improvement in environmental performance was found. Less than half of the analyzed indicators—namely, 48.27%—revealed a net improvement. Similarly, analysis of the justifications of the registered companies for the lack of improvement points to a rather symbolical adoption of the certification, intended to do only the bare minimum. These findings call into question the prevailing opinion about the positive impact of voluntary certifiable environmental management standards on environmental greening. Implications for managers and public policy makers, as well as for other stakeholders, are discussed.

Full text

Environmental Management Certification and Environmental Performance:
Greening or Greenwashing?1
Iñaki Heras-Saizarbitoria
Department of Management
University of the Basque Country UPV-EHU
Olivier Boiral
Department of Management
Université Laval
Alberto Díaz de Junguitu
Department of Applied Economics I
University of the Basque Country UPV-EHU
Abstract
This article analyzes the contribution of certifiable environmental management
standards—such as ISO 14001 and the Eco-Management and Audit Scheme (EMAS)—
to corporate environmental performance. Based on a content analysis of 414 third-party-
verified environmental statements from EMAS-registered Spanish organizations, which
included information for around 6,700 detailed indicators, a weak improvement in
environmental performance was found. Less than half of the analyzed indicators—
namely 48.27%—revealed a net improvement. Similarly, analysis of the justifications of
the registered companies for the lack of improvement points to a rather symbolical
adoption of the certification, intended to do only the bare minimum. These findings call
into question the prevailing opinion about the positive impact of voluntary certifiable
environmental management standards on environmental greening. Implications for
managers, and public policy makers, as well as for other stakeholders, are discussed.
Keywords: voluntary certifiable standards, environmental management systems,
certification, EMAS, ISO 14001, environmental performance, greenwashing.
Classification: Research paper.
1. Introduction
In the last two decades, many firms have adopted third-party certifiable Environmental
Management Systems (EMSs) based on voluntary international standards (Heras‐
Saizarbitoria and Boiral, 2013; Chiarini, 2017, 2019a; Baek, 2018; Wagner, 2019;
Lozano, 2019). Two main frameworks have been disseminated for this purpose: ISO
14001 and the Eco-Management and Audit Scheme (EMAS). The former was launched
in 1996 based on ISO 9001, its successful predecessor for Quality Management Systems
(QMSs). The latter was launched in 1993, came into force in 1995, and since then has
been adopted by thousands of European organizations, especially in Germany, Spain and
Italy (European Commission, 2019). From a practitioner perspective, although it is quite
1 This is a post‐peer‐review, pre‐copy‐edit author version of an article which has been published in its
definitive form in Business Strategy and the Environment and has been posted for personal use, not for
redistribution.
Heras
‐
Saizarbitoria, I., Boiral, O., & Díaz de Junguitu, A. (2020). Environmental management certification and
environmental performance: Greening or greenwashing?. Business Strategy and the Environment, 29(6),
2829-2841.

2
similar to ISO 14001 and fully compatible with the latest versions of that standard
(Neugebauer, 2012; Morrow and Rondinelli, 2002; European Commission, 2011), the
EMAS system is generally considered more demanding in terms of managerial
requirements (e.g., objectives, performance indicators, regulatory compliance). For
example, EMAS establishes the obligation to inform all stakeholders of the most
important environmental aspects as well as the operations carried out by the firm, for
which purpose a third-party validated or verified environmental statement is required
(European Commission, 2011). This statement had been referred to as one of the most
difficult aspects of EMAS for firms to implement (Hillary, 2004; Heras-Saizarbitoria et
al., 2020a), as they are not used to informing the public of internal facts about the
environment.
In both the practitioner and scholarly literatures, the adoption of certified EMSs has been
associated with better environmental performance (e.g., Testa et al., 2014; Boiral et al.,
2018; Wagner, 2019; Para‐González and Mascaraque‐Ramírez, 2019; Martínez et al.,
2019)2, following the general trend in the scholarly literature that establishes a connection
between the adoption of green practices and the improvement organization's performance
(e.g., Graafland and Smid, 2016; Franceschelli et al., 2019). Nevertheless, the findings
reported in the literature are not conclusive as this type of certification has also been
associated with the improvement of corporate image and legitimacy among stakeholders,
and greenwashing (e.g., Christmann and Taylor, 2006; Boiral, 2007; Heras-Saizarbitoria
et al., 2013; Vílchez, 2017; Testa et al., 2017; boiral et al., 2017; Iatridis and Kesidou,
2018), and it remains controversial. The process-focused rather than performance-
focused perspective of certifiable EMSs has been criticized, as these standards only
require firms to implement the systems or structures for monitoring environmental
aspects. The implementation of the standard is supposed to reduce environmental impact
(Bansal and Bogner, 2002; Boiral, 2007, 2011; Heras-Saizarbitoria et al., 2013), but the
certifiable EMSs do not set environmental performance levels, as underlined in the
scholarly literature (e.g., Boiral, 2011; Chiarini, 2017; Delmas, 2002; Iatridis and
Kesidou, 2018; Heras-Saizarbitoria et al., 2020b). Bansal and Bogner (2002) note that, ‘a
firm’s environmental performance could even deteriorate while the firm is certified’
(Bansal and Bogner, 2002; p. 282).
The adoption of ISO 14001 and EMAS has been the object of many empirical studies,
but the findings have been scattered and often contradictory, and do not necessarily lead
to a better understanding of the subject (Boiral et al., 2018). These inconsistent findings
lead to uncertainty as to whether or not the adoption of certifiable EMSs improves the
environmental performance (Fryxell et al., 2004: Iraldo et al., 2009; Zobel, 2016). This
has been also the case for ISO 9001 and QMSs (Heras-Saizarbitoria and Boiral, 2013;
Chiarini, 2019b). One of the possible explanations for this inconsistency has been related
to the methods used (Schylander and Zobel, 2003; Heras-Saizarbitoria and Boiral, 2013;
Nguyen and Hens, 2015; Boiral et al., 2018). There is a tendency to analyze the link
between EMSs and environmental performance based mainly on perceptions—in
particular the opinions of environmental managers—which may be influenced by social
desirability or self-reporting bias (Heras-Saizarbitoria and Boiral, 2013). For example, in
their literature review on the outcomes of ISO 14001, Boiral et al. (2018) found that
80.9% of the works studied used perceptual measures, while only 13.8% used data on
environmental impact. Therefore, doubts about the real, substantive or relevant impact of
certifiable EMSs to improve the environmental greening or performance of the certified
organizations, and the need to gather more different types of evidence, can be understood,
2 The adoption of certified EMSs has also been associated with better financial performance (e.g., Lee et
al., 2017; Endo, 2019; Riaz and Saeed, 2019; Yusof et al., 2020), despite the limitations of this type of
association (Heras-Saizarbitoria et al., 2011).

3
especially in the case of the EMAS scheme (Testa et al., 2014, 2018a; Heras-Saizarbitoria
et al., 2020a and 2020b).
Considering this gap in the literature, the aim of this study was to shed light on the real
contribution of certifiable EMSs to the environmental greening of certified companies.
The contribution of EMAS-based EMSs to the environmental greening of certified
companies, based on the verified detailed information reported by the EMAS-registered
organizations in their environmental statements, was analyzed. This paper contributes to
the scholarly literature in at least three ways. First, it contributes to the general research
field of certifiable EMSs and environmental performance, whose findings, as stated, have
been rather contradictory and inconclusive. Second, it contributes to the specific branch
of studies focusing on the adoption of the EMAS scheme, the strictest least researched
standard. Third, it proposes the use of the verified environmental statements associated
with EMSs and environmental reporting. This type of statement has been overlooked as
a way of examining the real contribution to greening of certifiable EMSs.
The remainder of this paper is arranged as follows. First, the literature review and the
research question are presented. Second, the methods of the analysis are summarized.
Third, the results of the analysis of EMAS-registered companies’ statements are
described. Fourth, the discussion and the conclusions are presented, and the original
contributions made by this research are identified.
2. Literature review and research question
Like the practitioner literature (e.g., Cascio et al., 1996; Dentch, 2016), most of the
general scholarly literature on environmental management associates the implementation
of ISO 14001 or EMAS certification with an improvement in the environmental
performance of the certified organization (e.g., Vachon and Klassen, 2006; Ambec and
Lanoie, 2008). Nevertheless, in the specialist literature of the field―which mainly
focuses on the adoption of ISO 14001-based EMSs, with only a few studies of EMAS
(Iraldo et al., 2009; Testa et al., 2009)―a general positive association between certifiable
EMSs and environmental greening or performance of organizations is suggested. (For
recent reviews on the impact of ISO 14001, see Boiral et al., 2018, Castka and Corbett,
2015, and Sartor et al., 2019, and for EMAS, see Tourais and Videira, 2016). This issue
has been widely debated and the overall results are inconclusive.
Among others issues, the superficial adoption of certifiable EMSs has been highlighted
by various studies based on a neo-institutional perspective (e.g., Boiral, 2007, 2011;
Aravind and Christmann, 2011; Heras-Saizarbitoria and Boiral, 2013; Vílchez, 2017;
Iatridis and Kesidou, 2018). From this theoretical perspective, the adoption of new
practices is intended to respond to institutional pressures and to reinforce organizational
legitimacy rather than improve the effectiveness of internal practices. As a result, in many
certified organizations, these practices can be considered “rational myths” (Boiral, 2007),
formal structures and statements which are rational in appearance but in fact somewhat
disconnected from internal practices and merely adopted symbolically for the sake of
appearances. Similarly, certain organizations adopt certifiable EMSs based on
international standards, such as ISO 14001 and EMAS, with the aim of obtaining a
commercial certificate or a sort of “organizational degree” mostly intended to influence
the perceptions of external stakeholders (Boiral, 2012). Such adoption of certifiable
EMSs, driven by the aim of improving external reputation in the eyes of a set of
stakeholders, has often been associated with greenwashing practices (Delmas and
Burbano, 2011; Potoski and Prakash, 2013; Boiral et al., 2017; Testa et al., 2018b).
Table 1 reviews the main findings of the scholarly literature that studies the impact of the
adoption of certifiable EMSs (i.e. ISO 14001, EMAS) on environmental performance.
The literature review reported in Table 1 focused on empirical quantitative studies

4
(qualitative studies were not included) published in English in international journals with
a peer-review system between 1996 and 2019. Key terms such as ‘ISO 14001’, ‘EMAS’,
and ‘EMS’ were used, together with keywords such as ‘environmental performance’,
‘outcomes’ and ‘benefits.’ Queries were made in the main electronic databases of the
management and environmental studies fields and through Google Scholar. The articles
obtained were analyzed in order to select those that study—either directly or indirectly—
the relationship between the adoption of certifiable EMSs and environmental
performance.
Table 1 illustrates the inconsistency in the findings mentioned above. To a certain extent,
this variety may be associated with the variables selected for the analysis and the methods
employed. Boiral et al. (2018) systematically reviewed close to 100 scholarly articles that
studied the outcomes of ISO 14001 and found that, among the articles focusing on the
impact on environmental performance, a wide range of variables were used in the
analysis: ‘Rigour and effectiveness of practices’ (21% of articles); ‘Waste minimization
and management’ (20%); ‘Air pollution’ (17%); ‘Environmental performance in general’
(15%); and ‘Regulatory compliance’ (15%). The use of diverse sources of information to
measure corporate environmental performance could therefore explain the lack of
consensus in findings.
Table 1: Studies on the link between certifiable EMSs and Environmental Performance
Article
Country
Sample
Measurement
Relationship*
Agan et al., 2013
Turkey
500
Perceptual
Improved
Al
-
Kahloot et al., 2019
Kuwait
16
Perceptual
Improved
Amran et al., 2014
Asia Pacific
111
Perceptual
Inconclusive
Aravind, 2012
US
192
Perceptual
Improved
Aravind & Christmann, 2011
US
72
Reported data
Inconclusive
Arimura et al., 2008
Japan
792
Perceptual
Inconclusive
Arimura et
al., 2011
Japan
945
Perceptual
Inconclusive
Arimura et al., 2016
Japan+US
478
Perceptual
Inconclusive
Babakri et al., 2004
US
177
Perceptual
Improved
Barla, 2007
Canada
37
Reported data
Unimproved
Biscotti et al., 2018
Europe
264
Reported data
Unimproved
Boiral & Henri, 2012
Canada
303
Perceptual
Unimproved
Cheng et al., 2019
China
253
Perceptual
Inconclusive
Comoglio & Botta, 2012
Italy
45
Perceptual
Inconclusive
Daddi et al., 2016
Europe
242
Reported data
Inconclusive
Demirel &
Kesidou, 2011
UK
289
Perceptual
Inconclusive
Ferrón
-
Vílchez, 2016
Global
1,214
Perceptual
Inconclusive
Franchetti, 2011
US
121
Perceptual
Improved
Graafland, 2018
Europe
3,633
Perceptual
Inconclusive
Gomez and Rodriguez, 2011
Spain
126
Reported
data
Improved
Heras
-
Saizarbitoria et al., 2016
Spain
361
Perceptual
Inconclusive
Iraldo et al., 2009
EU
101
Perceptual
Improved
Kawai et al., 2018
US, Europe
123
Perceptual
Improved
King et al., 2005
US
46,052
Perceptual
Unimproved
Link & Naveh,
2006
Israel
40
Perceptual
Improved

5
Source: Developed by the authors based on the reviewed studies. (*) Note: The term
‘Unimproved’ refers to articles that found a worsening of EP as well as works that did not find
any significant improvement. As the adoption of EMSs based on certifiable voluntary standards
aims at the continuous improvement of the organizations' performance, the term ‘Unimproved’
indicates that the main goal of the reference standard was not achieved.
Similarly, the use of contextual or moderating variables might influence the relationship
could be a potential source of variation in the outcomes of the studies. For example,
Arimura et al. (2016) found that the effectiveness of ISO 14001 certification differed
across institutional settings (e.g., institutional factors related to country differences and
differences in the type of environmental impacts). These authors found that the
effectiveness of ISO 14001 in reducing pollution varied across countries and also across
the type of environmental impact.
Yin and Schmeidler (2009) and Qi et al. (2012) for ISO 14001, and Testa et al. (2018a)
for EMAS found that the process of internalizing an EMS played an important role in
mediating the relationship between certification and environmental performance. In her
study of the impact of ISO 14001 on environmental and business performance in 7 OECD
countries, Ferrón-Vílchez (2016) also found that only ISO 14001-adopters who monitor
an extensive set of negative environmental impacts are associated with real improvements
in performance. In their study focused on US Transportation Equipment Manufacturers,
Nemati et al. (2016) found that ISO 14001 was effective in decreasing on-site pollution
for certain facilities, but was not effective in decreasing off-site pollution for any facility
considered in the study. Likewise, Testa et al. (2014) found that big organizations obtain
more benefit from the implementation of an EMS based on either ISO 14001 or EMAS
rather than another type of EMS. Finally, Erauskin‐Tolosa et al. (2019) performed a meta‐
analysis on the link between certifiable EMSs and environmental performance drawing
on a sample of 53 scholarly studies analyzing a total of 182,926 companies. Their findings
showed a positive influence of ISO 14001 and EMAS certification on corporate
environmental performance, but a set of underlying moderating effects were also
identified; there was a pronounced positive effect of adoptions based on environmental
innovation and for firms with a more mature certification.
Lastly, the main controversial aspects of the reviewed studies are associated with the
methods used to gather information about the impact of certifiable EMSs on
environmental performance. In their review, Boiral et al. (2018) found that the vast
Long & Lin, 2018
China
310
Perceptual
Inconclusive
Melnyk et al., 2003
US
911
Perceptual
Improved
Montabon et al., 2000
US
1,510
Perceptual
Improved
Montobbio & Solito, 2018
Europe
30,439
Reported data
Inconclusive
Nemati et al., 2016
US
678
Perceptual
Inconclusive
Nishitani
et al.,
2012
Japan
2,705
Reported data
Improved
Nguyen & Hens, 2015
Vietnam
56
Perceptual
Improved
Potoski & Prakash, 2005
US
3,709
Reported data
Improved
Qi et al., 2012
China
246
Perceptual
Inconclusive
Russo, 2009
US
530
Perceptual
Improved
Singh et al., 2015
India
63
Perceptual
Improved
Testa et al., 2014
Italy
229
Perceptual
Inconclusive
Testa
et al.,
2018a
EU
224
Reported data
Inconclusive
Yin &
Schmeidler, 2009
US
456
Perceptual
Inconclusive
Zobel, 2016
Sweden
116
Perceptual
Unimproved

6
majority of empirical studies used perceptual measures obtained by surveys to analyze
the impact of certifiable EMSs on environmental performance. This issue is also reported
in Table 1, which shows that most of the reviewed empirical studies were based on
perceptual measures. These perceptual measures may be influenced by social desirability
bias and self-proclaimed benefits from environmental managers to closed-ended
questions included in questionnaires. A common example is the assessment of the impact
of EMSs on environmental performance through a 1-5 Likert scale. This type of self-
reported perceptual measure is prone to several distortions and biases, as underlined in
the specialized literature (e.g., Heras-Saizarbitoria and Boiral, 2013; Boiral et al., 2018).
Therefore, there is a need to develop new ways to gather reliable information about the
impact of EMSs on environmental performance. One possibility is to focus on the
validated information provided by EMAS-registered companies in their public
environmental statements. To our knowledge, this perspective has not been applied yet to
the study of the relationship between EMSs and environmental performance. The analysis
of validated EMAS environmental statements has been used very little in previous work
on environmental reporting that aims to analyze the characteristics (e.g., reliability,
comparability) of the reported environmental indicators (Marsanich, 1998; Erkko et al.,
2005; Bonilla-Priego and Avilés-Palacios, 2008; Petrosillo et al., 2012; Mazzi et al.,
2012). As a result, to our knowledge, the measurement of the success of an EMS
certification scheme, such as EMAS, in terms of tangible environmental
improvements―as proposed many years ago by Hillary (1999)―has not been addressed
yet in the literature. Based on the theoretical and empirical considerations found in the
scholarly literature, the following main research question is proposed: In the light of their
performance reported in the verified environmental statements, do EMAS-registered
companies improve their environmental performance?
3. Methods
To address the research question, an exploratory empirical study was planned. Spain was
the geographical focus of the study, as it is one of the member states of the European
Union with most EMAS certification (Heras-Saizarbitoria et al., 2015).
The data from 414 statements issued by EMAS-registered companies was obtained from
the EU EMAS Helpdesk service of the European Commission and from the websites of
those registered companies. The EMAS scheme establishes that the environmental
statements are public and therefore anyone should have access to them easily and free of
charge. Most of the statements were then obtained from the companies’ websites, but
around 10% were more difficult to obtain, as the companies did not publish them on their
websites. In these cases, we requested them by e-mail or telephone. Of the initially
identified companies, five were reluctant to provide us with their environmental
statements.
Companies operating in six sectors of activity were selected: Building; Chemical; Food
& Beverage; Printing; Retail Trade; and Tourism. These sectors of activity were chosen
due to their high environmental impact and their high number of EMAS registrations
(Heras-Saizarbitoria et al., 2015). To give a broad and rich picture of the impact of the
adoption of EMSs on environmental performance of EMAS-registered companies, the
analysis was carried out in two stages. The first stage was performed in 2013 and the
second in 2019. The statements analyzed in the first stage ranged from 2007 to 2009,
while the statements analyzed in the second stage ranged from 2015 to 20193. In the first
3 EMAS- registered companies aredid not published the environmental statements once eachimmediately
at the end of the reference year, is finished but only withafter a delay lag, which was higherlonger before

7
stage, 160 statements/companies were analyzed. In the second stage, 254
statements/companies were analyzed. In common with most studies of the adoption of
voluntary certifiable standards, such as EMAS and ISO 14001, the present study includes
companies have been using their EMSs for different periods of time - a variable measured
as the time elapsed from the first EMAS registration. This was used as a control variable
in order to try to detect potential biases, together with other variables such as the size of
the firm and the location of the firms in Spain (as many public policies that may affect
companies are regional)4.
These data were included in the analysisere because, as underlined in the previous section,
they might shed light on the potential of the EMAS-registered companies to improve their
environmental performance with externally verified data. The analysis was to shed light
on the specific environmental aspects and the main environmental objectives and targets
established by EMAS- registered companies following the requirements of the scheme
used verify the EMS. For example, registered companies informdisclosed information
about the main key performance indicators (KPIs)5 etoused to monitor their
environmental performance and their continuous environmental improvement. T the
EMAS scheme setsstates that registered organizations should be able ‘to demonstrate an
improvement of their environmental performance’ (EC, 2009). Unfortunately, it was not
possible to setestablish a control group for the set of companies that was analyzed (i.e. a
group of non-EMAS- registered companies), as the the type of environmental information
disclosed by the data needed for such an exercise is only publicly available for EMAS-
registered companiesis.
The analyzed EMAS environmental statements were quite similar with respect to their
appearance and structure, although they varied in terms of length (about 40 pages on
average). Their typical structure included sections similar to the following ones:
Introduction (presentation of the company and the statement); Description of the EMS;
Environmental Policy; Environmental aspects and impacts; Objectives, targets and
actions; Environmental performance indicators—with the defined targets and a
description of the objectives' level of achievement for each KPI—; Legal requirements;
and Communication. Although the analysis was carried out for two different time periods,
there were no significant differences either in terms of content (e.g., structure, KPIs,
targets) or the average length of the statements.
Table 2 summarizes the number of companies and indicators analyzed as well as their
sectoral breakdown. Overall, the verified environmental statements of 414 EMAS-
registered companies from six sectors of activity and 6,770 indicators of environmental
performance disclosed by these companies were analyzed. When reference is made to a
specific environmental performance indicator, it generally means the result of a given
indicator for a given period of time (usually one year).
Table 2: Sectoral breakdown of analyzed organizations and indicators by fieldwork
stage
2013 2019 Total
Sector No. of firms No. of indicators
No. of
firms
No. of indicators
No. of firms No. of indicators
the EMAS III regulation came into force. The analyzed statements were published in the so-called EMAS
Library ofby the European Commission. This information is provided in the revised version of the article.
4 This information was also provided by the EU EMAS Helpdesk.
5 The EMAS scheme establishes that the KPIs shall focus on the performance of the following key areas:
Efficiency use of materials; Energy efficiency; Water management; Waste management; Biodiversity;
Emissions into the air; and Other relevant indicators (EC, 2009).

8
Building 37 507 45 720 82 1,227
Chemical 24 484 26 546 50 1,030
Food & Beverage 14 294 36 792 50 1,086
Printing 11 159 14 224 25 383
Retail Trade 10 236 11 242 21 478
Tourism 64 858 122 1,708 186 2,566
Total 160 2,538 254 4,232 414 6,770
Source: prepared by the authors
All the environmental statements retrieved for the purpose of the content analysis were
published as PDF documents. The documents scanned as images were converted to text
using OCR software and the final sample of text analyzed represents approximately 5,500
single-spaced pages. This information was extracted, categorized, and analyzed by two
researchers using an analysis grid. The qualitative and quantitative information for each
EMAS statement was compiled into a set of Excel spreadsheets. As suggested in the
specialist scholarly literature (Schreier, 2012), the information was then reviewed
separately by a third researcher with an assessment protocol in order to improve the
validity and reliability of the analysis.
The main information contained in the analysis grid consisted of: (1) the environmental
performance indicators of each EMAS-registered organization (see Table 3 in the next
section for a sample of the most frequently used environmental performance indicators)
and (2) the descriptive, qualitative explanation for the compliance or non-compliance
with the proposed environmental objectives for each indicator. At each stage of the
fieldwork (i.e. the analysis of data collected in 2013 and in 2019), the environmental
statements were used to determine whether or not the environmental performance
indicators had improved over the previous year. Similarly, the explanations given by the
EMAS-registered company were also analyzed. The descriptive, qualitative information
was analyzed using a process of systematically classifying the data (Schreier, 2012) based
on a qualitative content analysis, which was used to interpret textual information through
a systematic process of categorization that groups information around recurring concepts
or themes. The data analysis process followed these steps: extraction and collection of
information from the environmental statements; development of the framework of
categories; categorization; analysis and interpretation of information and the selection of
illustrative quotations.
In the following section, the main findings of this analysis are summarized, combining
descriptive statistical techniques with the outcomes of the content analysis of verified
environmental statements (Mayring, 2004).
4. Results
Table 2 summarizes the number of companies and indicators analyzed, as well as their
sectoral breakdown. Overall, 6,770 environmental performance indicators from the
EMAS-registered companies' verified environmental statements were analyzed. When
reference is made to a specific environmental performance indicator, it generally means
the result of a given indicator for a given period of time (usually one year). Table 3 shows,
as an illustrative example, some of the most frequently used performance indicators
included in the environmental statements*FOOTNOTE. This should make clear the
nature of the environmental performance indicators analyzed. The performance indicators
changed very little between the first and the second stages of the study.

9
Heras-Saizarbitoria, I., García, M., Boiral, O., & de Junguitu, A. D. (2020c). The use of eco-
efficiency indicators by environmental frontrunner companies. Ecological Indicators, 115,
106451.
Heras-Saizarbitoria, I., Boiral, O., García, M., & Allur, E. (2020b). Environmental best practice and
performance benchmarks among EMAS-certified organizations: An empirical
study. Environmental Impact Assessment Review, 80, 106315.
*The analysis was focused on relative indicators set with minimum eco-efficiency criteria —i.e.
combining economic value and environmental impact (Heras-Saizarbitoria et al., 2020b).
Table 2: Sectoral breakdown of organizations and indicators analyzed by fieldwork
stage
2013 2019 Total
Sector No. of firms No. of indicators
No. of
firms
No. of indicators
No. of firms No. of indicators
Building 37 507 45 720 82 1,227
Chemical 24 484 26 546 50 1,030
Food & Beverage 14 294 36 792 50 1,086
Printing 11 159 14 224 25 383
Retail Trade 10 236 11 242 21 478
Tourism 64 858 122 1,708 186 2,566
Total 160 2,538 254 4,232 414 6,770
Source: prepared by the authors
Table 3: Variation of the environmental performance indicators by sector and fieldwork
stage
2013 2019
Sector % of
improved
indicators
% of
unimproved
indicators
% improved
of indicators
% of
unimproved
indicators
Building 53.06% 46.94% 47.41% 52.58%
Chemical 49.60% 50.40% 49.03% 50.97%
Food & Beverage 50.68% 49.32% 38.26% 61.74%
Printing 56.60% 43.40% 47.77% 52.23%
Retail Trade 48.73% 51.27% 47.11% 52.89%
Tourism 48.37% 51.63% 42.56% 57.43%
Total 51.17% 48.83% 45.36% 54.64%
Source: prepared by the authors

10
Table 4: Sample of the most frequently used indicators of environmental performance
by key area
Key area or KPI
Indicator (units)
Efficiency of material consumption Total direct use of raw materials/Total annual
production (kg/weight, volume, value or number of
products)
Total direct use of /Total annual production
(MWh/production units)
Energetic efficiency Total direct energy use/Total annual production
(MWh/production units)
Total energy use per product unit (kWh/weight,
volume, value or number of products)
Total use of renewable energy/Total annual
production (MWh/production units)
Water management Total annual water consumption/Total annual
production (m³/production units)
Waste management Total annual generation of waste/Total annual
production (kg/weight, volume, value or number of
products)
Biodiversity Total use of land (m2 of built-up area)
Emissions into the air Total annual emissions of GHG/Total annual
production (kg CO2eq/weight, volume, value or
number of products)
Source: prepared by the authors
The analysis of environmental performance indicators shows that these indicators were
mostly unimproved in EMAS-registered organizations for both stages of the study. This
failure to achieve environmental objectives may be interpreted as non-compliance with
the requirements of the EMAS scheme, as registered organizations should be able ‘to
demonstrate an improvement of their environmental performance’ (EC, 2009).
Indeed, as shown in Table 5, a deterioration in the environmental performance indicators
analyzed can be observed between the two periods in which the analysis was performed,
from an average 51.17% of indicators improving in 2013 to an average of 45.36% in
2019. On a sectoral basis, the worsening was generalized but with a set of remarkable
cases, such as the case of certified companies in the Food & Beverage sector, which
experienced a worsening of more than 10 percentage points for some indicators.
Regarding the control variables, no decrease of EMAS benefits over time was detected in
EMAS-registered companies, as the years of experience with EMAS registration did not
significantly impact the improvement or lack of improvement of the targeted

11
environmental performance indicators. The effect of company size and regional
distribution was also statistically insignificant6.
Table 5: Variation of the environmental performance indicators by sector and fieldwork
stage
2013 2019
Sector % of
improved
indicators
% of
unimproved
indicators
% improved
of
indicators
% of
unimproved
indicators
Building 53.06% 46.94% 47.41% 52.58%
Chemical 49.60% 50.40% 49.03% 50.97%
Food & Beverage 50.68% 49.32% 38.26% 61.74%
Printing 56.60% 43.40% 47.77% 52.23%
Retail Trade 48.73% 51.27% 47.11% 52.89%
Tourism 48.37% 51.63% 42.56% 57.43%
Total 51.17% 48.83% 45.36% 54.64%
Source: prepared by the authors
Figure 1: Total of improved and unimproved environmental performance indicators by
sector
6 Descriptive and deductive statistical methods were used (e.g. variance and correlation analyses,
regression analysis) in order to test the statistical significance of the variables.

12
Source: prepared by the authors
In short, the figures for the analyzed certified companies may be considered weak, in both
2013 and 2019. As shown in Figure 1, with the exception of the Building and Printing
sectors, the average percentage of unimproved environmental performance indicators was
higher than the percentage of improved indicators. These figures may be considered as
weak or bad considering that the analyzed companies are supposed to be leading
companies in terms of environmental awareness and introduction of environmental
practices (Heras-Saizarbitoria et al., 2020). It should also be noted that the environmental
practices mentioned in the public environmental statements have not only been evaluated
by the staff of the EMAS-registered organization, but also by an experienced external
third-party.
Table 6: Variation of justified and unjustified indicators by sector and fieldwork stage
2013 2019
Sector % of
justified
indicators
% of unjustified
indicators
% of
justified
indicators
% of unjustified
indicators
Building 36.55% 63.45% 44.92% 55.08%
Chemical 52.87% 47.13% 44.43% 55.57%
Food & Beverage 43.45% 56.55% 49.73% 50.27%
Printing 4.35% 95.65% 16.31% 83.69%
Retail Trade 71.90% 28.10% 20.62% 79.38%
Tourism 42.21% 57.79% 31.06% 68.94%
Total 44.13% 55.87% 34.51% 65.49%
Source: prepared by the authors.
As stated, beyond this descriptive study, a descriptive and qualitative content analysis
was carried out with regard to the justifications given by the EMAS-registered companies
when environmental performance indicators were not improved. Table 5 summarizes the
figures for the justified and unjustified indicators and Table 6 shows a set of illustrative
justifications made by certified companies.
By sector, Table 6 shows that for the two stages considered—except for Retail Trade and
Chemical in 2013—there were more unjustified than justified indicators for the EMAS-
registered companies. Overall, the negative performance on indicators remained mainly
50.24% 49.32%
44.47%
52.19%
47.92% 45.47% 48.27%
49.76% 50.69%
55.53%
47.82%
52.08% 54.53% 51.74%
0.00%
10.00%
20.00%
30.00%
40.00%
50.00%
60.00%
Building Chemical Food & Beverage Printing Retail Trade Tourism Total
% improved indicators % non‐improved indicators

13
unjustified. As the unjustified negative results have increased from 55.87% in 2013 to
65.49% in 2019, the accountability of these statements has not improved over time.
Table 7: Illustrative justifications by sector and fieldwork stage
Justifications included in the environmental statements (stage)
Building ‘Growth in consumption of raw materials, possibly due to increased workload.’ (2013)
‘The reason for the increase [in fuel consumption] is due to a greater number of rented vehicles.’ (2019)
‘Cardboard production has increased due to the greater number of jobs linked to business line [name omitted].’
(2019)
Chemical ‘The increase in consumption is due to leaks in the system's pipes.’ (2013)
‘There is a slight upward trend, due to the introduction of new equipment and facilities, necessary for the
increase in production capacity.’ [Note: there was a strong increase of 5%, twice the increase in production of
the section concerned]. (2019)
‘Removals from many departments that generated a large amount of paper waste.’ (2019)
Food &
Beverage
‘There is evidence of increased electricity consumption as production at the facility increases.’ (2013)
‘The worsening of data is due to the installation and adjustment period of a new washer with a higher flow.’
(2013)
‘The introduction of a new and less efficient machine for the manufacture produced a worse performance.’
(2019)
Printing ‘Growth in electricity consumption due to the expansion of offices [...] although total production is not increasing
much.’ (2013)
‘Because water is used in the community areas by the various tenants of the building, it is impossible to know the
[growing] consumption derived from the activities and personnel of the company.’ (2019)
‘Electricity consumption per end product is worsened by production inefficiencies.’ (2019)
Retail
Trade
‘[The increase in electricity consumption was due to] a leak in the air conditioning circuit.’ (2013)
‘The slight increase observed in the summer months compared to the winter months is due to the implementation
of air conditioning and the increased demands on the cooling circuit due to heat.’ (2019)
‘Exchange of glass containers for plastic ones.’ (2019)
‘Loss of water due to possible breakdowns in the circuits.’ (2019)
Tourism ‘Breakdown in the recirculation pump of the purification system.’ (2013)
‘Breakages and leaks in the pools.’ (2013)
‘More optimal days for recreational boating.’ (2019)
‘Lack of common sense in the use of pool towels.’ (2019)
‘Replacement of shower curtains with screens that require daily cleaning.’ (2019)
‘Incorporation of 3 osmosis machines and 23 new Jacuzzis.’ (2019)
Source: prepared by the authors
Table 7 shows some of the illustrative justifications obtained in the qualitative analysis.
In general, it was found that the justifications given were neither very detailed nor very
rigorous. These justifications can be classified into four types: (1) increase in activity; (2)
environmentally inefficient changes; (3) tautology; (4) hypocrisy.
(1) For around 50% of the justifications provided in the statements, the poor
performance on indicators is justified by an increase in activity, for example in
the final or intermediate production, which in turn seems to require—at least in

14
the perception of the analyzed companies—an increased use of resources. It is
interesting to note in this respect that a very small number of indicators for the
companies studied were of the eco-efficiency type (Erkko et al., 2005). Among
the most common justifications were leaks and breakdowns. Very few companies
emphasised that they either had preventive maintenance plans or that they plan to
implement them to avoid this type of problem.
(2) Many justifications (around 30%) also refer to changes introduced in
organizations that were questionable from the perspective of environmental policy
and more advanced practices in this field. This is the case, for example, in the
tourism sector where on one occasion the growth in electricity consumption was
justified by the ‘need to introduce tumble dryers in all rooms.’ Or the case of an
EMAS-registered company from the Retail trade sector that justified the growth
in the generation of plastic waste due to the ‘exchange of glass containers for
plastic ones.’
(3) For a number of justifications (around 10%), the explanations released in the
statements could be qualified as tautological, with statements such as: ‘waste
management performance has worsened due to an increase in hazardous waste
generated.’ In some cases, surprising and paradoxical justifications were found.
For example, a company in the chemical sector justified its increase in paper
generation ‘because of the elaboration and distribution of the procedures of the
Quality and Environmental System.’
(4) Finally, in a percentage of cases (around 10%), the justifications provided did not
correspond to reality, even though they were extracted from externally verified
reports. For example, the existence of particularly hot summers is argued to justify
the increase in electricity consumption (due to an allegedly higher use of air
conditioning), when, according to official data from the Spanish meteorology
agency (AEMET, 2020), this was not the case. Justifications were also given
based on assertions that cannot be confirmed in light of the company's own data
detailed in their environmental statement.
5. Discussion and conclusions
This article analyzes the contribution of a strict certifiable EMS, namely EMAS, to
corporate environmental performance. Based on a content analysis of 414 third-party
verified environmental statements from EMAS-registered Spanish organizations, which
included information for 6,770 detailed indicators, a weak improvement of environmental
performance was found, as less than half of the analyzed indicators revealed a net
improvement of the environmental performance. Similarly, the analysis of the
justifications for the lack of improvement on indicators by the registered companies may
point to a rather symbolical adoption of the certification by a relevant percentage of
registered companies since, when such justifications exist—which only happens in
39.32% of the cases—they are not rigorous and well-founded.
These findings are consistent and complementary with other contributions of the
scholarly literature (e.g., Boiral, 2007; Heras-Saizarbitoria et al., 2013; Testa et al., 2018;
Heras-Saizarbitoria et al., 2020). According to a recent systematic literature review in the
field of voluntary certifiable standards for EMSs (Boiral et al., 2018), although the
dominant scholarly literature is optimistic with regard to the impacts of these certifiable
standards, an increasing body of research questions their effectiveness. As it has been
pointed out by the neo-institutional literature on certifiable EMSs such as ISO 14001 and
EMAS (e.g., Yin and Schmeidler, 2009; Heras-Saizarbitoria et al., 2013; Iatridis and
Kesidou, 2018; Testa et al., 2018; Heras-Saizarbitoria et al., 2020b), many companies use
these standards just to obtain the certification, which is used as an organizational degree
(Boiral, 2012), i.e. a tool to strengthen the firm’s social legitimacy—a concept associated

15
with greenwashing—rather than to improve internal practices and environmental
performance.
Generally speaking, this work contributes to the branch of the literature questioning the
prevailing opinion about the positive impact of voluntary certifiable EMSs on
environmental greening. Similarly, this article contributes to the scholarly literature on
both voluntary certifiable EMSs and environmental reporting and corporate disclosure as
it proposes an overlooked methodological approach (related to data collection), which
avoids common distortions and biases such as the social desirability bias associated with
the use of perceptual data. This study also contributes to the literature on the neo-
institutional approach to EMSs and the greenwashing tendencies associated with
certification practices (e.g., Testa et al., 2018; Martín-de Castro et al., 2016; Iatridis and
Kesidou, 2018). Most research in this area has criticized the use of certifiable EMSs as a
marketing tool with uncertain or little impact on internal practices and environmental
performance. Nevertheless, the information on these impacts are difficult to obtain and
tend to be shaped by the greenwashing tendencies of organizations (Boiral, 2007).
It seems unlikely that the explanations given in the EMAS statements analyzed in the
present study are significantly biased by the same greenwashing tendencies for at least
three interrelated reasons. First, it is reasonable to assume that such tendencies would
have resulted in the disclosure of substantial improvements in environmental
performance, which is clearly not the case for the majority of the statements analyzed.
Second, although most EMAS statements are publicly available, they are not publicized
by companies (Heras-Saizarbitoria et al., 2020) and stakeholders tend to ignore their
existence. As a result, the information contained is not really used by stakeholders to exert
pressure on certified companies, or to require better environmental performance and more
detailed explanations in this area. This lack of external pressure related to the content of
EMAS statements does not encourage greater accountability from certified companies
with regard to environmental issues, which could explain why the reported performance
has not significantly improved over time. Third, the EMAS statements seem to be used
by certified companies to comply with the requirements of the standards and for auditing
purposes. Despite the need to exercise caution in interpreting the results, the findings
point to a lack of significant improvement in environmental performance, and the lack of
substance in most of the explanations provided by companies suggests that the indicators
published in the statements could have not been used as an effective internal tool to
improve practices and correct deviations from environmental objectives.
The findings of this study have many implications for managers, policy makers, and other
stakeholders. Considering the results of this study, managers should be aware of the actual
or day-to-day limitations of third-party certification schemes in motivating the adoption
of advanced environmental practices. They should also be aware of the heterogeneous
behaviours of the parties involved in the verification and audit of EMSs, including those
that allow a symbolic adoption of these tools without representing a substantial
improvement in environmental practices and performance.
For policy makers, these results once again underline the need to rethink policies that
promote the indiscriminate adoption of certifiable voluntary schemes for environmental
management. They also underline the importance of establishing adequate public
monitoring and evaluation programmes to analyze the real impact of those programmes
for corporate environmental performance. There is also a need to rethink public policies
associated with this type of tool, such as regulatory relief policies for certified companies
(Testa et al., 2016).
Regarding other stakeholders, the findings might be of interest to consumer groups, such
as the European consumer groups who have been critical of voluntary third-party
certification schemes such as EMAS. The criticism of these groups with regard to the

16
‘lack of performance requirements and the absence of a mandatory set of comparable
performance indicators which would allow for a differentiation between good and bad
performers’ (ANEC, 2006; p. 1) seems reasonable in the light of the evidence collected.
The inclusion of sectoral benchmarks and best practices does not appear to have benefited
registered companies much, at least on the evidence in the literature (Heras-Saizarbitoria
et al., 2020). Despite the limits of certifiable EMSs and criticism on their lack of
effectiveness, in the case of the EMAS standard, stakeholders could pay more attention
to the statements released by companies. The lack of reported benefits could be used by
stakeholders who are really concerned by environmental issues as a leverage to exert
pressure on companies and to require more corporate accountability on environmental
performance.
This study has a number of limitations due to its exploratory nature and its limited
geographical scope. The research design of the study could have been substantively
improved if a control group of non-EMAS-registered firms could have been included in
the analysis. But this type of analysis is very difficult, if not impossible, due to the
difficulties in obtaining this type of sensitive data from companies. Similarly, the sample
of certified companies was drawn from a set of sectors of activity in a specific country
where the dissemination of EMAS has been high (Heras-Saizarbitoria et al., 2015), and
this is also a limitation of the study. Therefore, the findings of this study may not be
generalizable to other sectors of activity or to other countries, even though some
isomorphic behaviour has been reported in the scholarly literature (Heras-Saizarbitoria
and Boiral, 2013) among organizations from different geographical areas. The limitations
of this work suggest avenues for future research. In addition to extending the geographical
scope of the analysis to other countries, it would be interesting to extend the analysis to
other voluntary certifications schemes such as ISO 14001. The potential for using control
groups, using information from non-certified firms that they disclose on environmental
performance indicators to meet legal requirements — e.g., in complaince with the
Integrated Pollution Prevention and Control directive in the EU — and voluntary drivers
— e.g., the publication of sustainability reports based on reference models such as
guidelines of the Global Reporting Initiative — might also be analyzed.
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