g AmazonImpact.

Illumination Index
19/22

Lower values indicate greater alignment. Higher values indicate more gaps detected.

The Index evaluates how clearly a company’s sustainability communications align with available evidence. It does not measure the company’s overall sustainability performance or determine the company’s intent.

What The Index Examined:

Amazon communicates extensively about climate action, renewable energy, transportation and its commitment to reach net-zero carbon emissions by 2040 through The Climate Pledge.

The Illumination Index compared those public commitments with Amazon’s reported emissions data, third-party climate records and changes to previously announced sustainability goals.

Part A - Communication Pattern Analysis

10/12

Part B - Claims vs. Data Comparison

9/10

Key Finding

Pattern Identified

Amazon publishes extensive sustainability information, but several important developments provide a more complicated picture than its climate commitments alone. During the research period, total emissions remained about 34% above the 2019 Climate Pledge baseline, Amazon’s Science Based Targets initiative (SBTi) commitment was removed after the target-setting period expired, and Shipment Zero was discontinued as a separate goal. Financial filings also show major AWS infrastructure expansion, while a pending class action challenges environmental labels on certain Amazon Basics paper products. These findings appear across different public sources rather than within one connected sustainability narrative

What This Pattern Means

For consumers, Amazon shows why a large amount of sustainability disclosure does not necessarily provide all of the relevant context in one place. A consumer may see Amazon’s 2040 net-zero commitment without also seeing that total emissions remain above its original baseline or that earlier climate commitments have changed. The Illumination Index brings emissions data, third-party records, company updates, financial filings and relevant legal records together so consumers can see what Amazon currently promises, what has changed and what the broader evidence shows about its progress.

What The Illumination Index Found

Amazon co-founded The Climate Pledge in 2019 with a commitment to reach net-zero carbon emissions by 2040. During the research period, its reported absolute emissions remained about 34% above the 2019 baseline. Amazon also reported improvements in carbon intensity, but intensity and total emissions measure different outcomes.

1

Amazon’s SBTi commitment status changed.

Amazon previously committed to setting science-based emissions targets through the Science Based Targets initiative (SBTi). After the target-setting period expired, SBTi changed the commitment status to “Commitment Removed.” The Illumination Index examines whether changes like this to major third-party climate commitments are clearly reflected in a company’s public sustainability communications.

2

AWS (Amazon Web Services) infrastructure investment provides additional context.

Amazon previously pledged to make 50% of shipments net-zero carbon by 2030 through Shipment Zero. The company later discontinued Shipment Zero as a separate goal and published an update explaining the change. The Index examines whether major changes to earlier sustainability commitments are communicated clearly and prominently across the company’s broader materials.

3

Shipment Zero was discontinued.

Amazon reported approximately 96.5 billion in net additions to property and equipment for AWS in 2025. Amazon also states that much of its technology infrastructure investment such as data-centers and servers support AWS growth. These disclosures provide important context for evaluating how the company communicates the relationship between AWS's rapid infrastructure growth, increasing energy needs and its climate commitments.

4

Absolute emissions remain above the Climate Pledge baseline.

A 2025 proposed class action alleges that Amazon displayed the FSC certification logo and Climate Pledge Friendly label on certain Amazon Basics toilet paper and paper towels even though some of the wood pulp was allegedly sourced through clear-cutting and burning in Canada’s boreal forest. The lawsuit argues that these labels could give consumers a more sustainable impression of the products than the underlying sourcing practices supported. The Illumination Index includes the case because it directly concerns whether Amazon’s consumer-facing sustainability labels align with the sourcing practices and evidence behind those claims. The case is still pending, so the allegations have not been established as findings of wrongdoing.

5

A class action challenged environmental product claims.

Indicator Breakdown

Each indicator: 0 = not detected · 1 = partially present · 2 = clearly and systematically present. Illumination Index values are not derived from impressions . Every indicator is anchored to a specific source.

    Part A · Communication Pattern Analysis
    10 / 12
  
Vagueness
Claims with no measurable meaning, baseline, or threshold
Lack of quantification
Boldest consumer-facing claims cannot be traced to a baseline year or unit of measurement
Selective disclosure
Reporting patterns that omit unflattering data points or material information
Future deflection
Future commitment language used in place of present-year performance data
Third-party verification
Absence or misrepresentation of independent validation credentials
Cross-platform inconsistency
Gaps between consumer-facing communications and formal report content

    Part B · Claims vs. Data Comparison
    9 / 10
  
Emissions trajectory vs. reduction claims
Whether actual emissions trend aligns with stated targets and timelines
Carbon neutrality and net zero claim integrity
Whether commitments are backed by specific offsets, timelines, and operational infrastructure
Omission of material controversies
Regulatory bans, court rulings, or legal proceedings absent from sustainability communications
ESG ratings volatility
Year-over-year changes across independent rating agencies that diverge from stable marketing claims
TCFD completeness
Coverage across all four Task Force on Climate-related Financial Disclosures pillars

What is ESG?

ESG stands for Environmental, Social and Governance. It is a broad way of looking at how a company affects the environment, treats people and communities, and manages leadership, oversight and accountability.

What is the TCFD?

TCFD stands for Task Force on Climate-related Financial Disclosures. It is a framework that helps companies explain how climate-related risks and opportunities could affect their business, strategy and financial planning. TCFD helps make climate reporting easier to evaluate and compare.

References

Amazon. (2024). 2024 sustainability report. https://sustainability.aboutamazon.com/

Amazon. (2024). Annual report pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 (Form 10-K). U.S. Securities and Exchange Commission. https://ir.aboutamazon.com/annual-reports-proxies-and-shareholder-letters/annual-reports/default.aspx

Amazon Ads. (n.d.). How advertisers can connect with shoppers with sustainable marketing. https://advertising.amazon.com/blog/sustainable-marketing

CDP. (n.d.). Amazon CDP disclosure [Database]. https://www.cdp.net/en/responses

InfluenceMap. (2025). Amazon: Climate policy engagement [LobbyMap database profile]. https://lobbymap.org/company/Amazon

Net Zero Tracker. (n.d.). Amazon [Database entry]. Energy & Climate Intelligence Unit, Oxford Net Zero, NewClimate Institute, & Data-Driven EnviroLab. https://zerotracker.net

Science Based Targets initiative. (n.d.). SBTi target dashboard [Database]. https://sciencebasedtargets.org/companies-taking-action

The Climate Pledge. (n.d.). About The Climate Pledge. https://www.theclimatepledge.com/us/en/the-pledge