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The 2025 DISCOMFORT REPORT: CROCS’ DECREASED AMBITION, PACKAGED AS PROGRESS 

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Recently, Crocs published its 2025 sustainability report — the Comfort Report — framing bio-circular materials as its core strategy for cutting the company’s largest source of emissions, and presenting itself as a company sustaining, even deepening, its climate ambition. But the underlying target tells a different story: Crocs has quietly scaled back its materials goal, using accounting and semantic shifts that make the reduction nearly invisible to anyone not reading closely. 

This is our response — a Discomfort Reportthat lays out exactly how that shift happened, and what it means for a company that’s positioning itself as a sustainability leader.

1. Semantic Tricks: Crocs quietly shrank its climate goal, but kept the same headline target  

Crocs’ shoes are made mostly from fossil fuel-derived materials, including EVA and polyolefin elastomers. It’s no surprise, then, that raw materials account for a significant share of the company’s emissions. According to its own reporting, 98% of Crocs’ emissions come from Scope 3 — that is, indirect upstream and downstream emissions. The largest contributor is Category 1: Purchased Goods and Services, which includes the extraction and production of raw materials. 

Recognising this challenge, Crocs announced a materials target in 2022: by 2030, Crocs would replace 50% of the fossil-derived inputs in the proprietary material used in most of its footwear, Croslite™, with “bio-circular” alternatives. By focusing on Croslite™ as a whole, this target would ensure that most of Crocs’ product catalogue would be included in the transition to lower-carbon materials. 

In its 2025 sustainability report, this changed. In it, Crocs reveals that it has “narrowed the scope of this goal” (p.6), and it now aims to reach 50% of bio-circular materials in its Classic Clogs line only. 

The headline target remains unchanged at 50% by 2030, appearing on the surface as sustained ambition. And yet, there has been a significant reduction in ambition: achieving 50% bio-circular content within just one product category requires substantially less investment and fewer low-carbon inputs than applying the same target across the wider product portfolio that is made with Croslite™. 

In fact, in 2025 Crocs actually used less bio-circular materials than in previous years. While the report talks about a focus on “increasing bio-circular materials” and “incremental progress” (p.7), on a buried note on p.21, you’ll find an asterisk that clarifies that, despite this claim, in 2025, emissions from Croslite compounds increased, primarily driven by a decreased use of bio-circular materials overall”

This contradiction is concerning. By using carefully selected language to around their climate goals, Crocs is simultaneously reporting lower overall use of bio-circular materials, rising materials-related emissions, and a reduced scope for its materials target — while presenting these developments as sustained climate ambition.  

Equally concerning, however, are the accounting and emissions reporting systems that are making this illusion of progress possible. 

2. Accounting Tricks: Crocs used mass balance accounting to make its shoes look more bio-circular than they really are

In 2024, Crocs reported that it had reached 25% bio-circular content in its Croslite™ material on a mass balance basis. Mass balance accounting allows Crocs to purchase materials with “bio-circular” paper credits attached to them, not necessarily actual bio-circular materials. In fact, because of the use of mass balance, the shoes that Crocs has been marketing as 25% bio-circular since 2024 could be much closer to containing 100% fossil-fuel plastic. Check out our report for a detailed examination of how Crocs uses mass balance accounting, and why your Crocs might actually contain zero “bio-circular” content. 

The extent of how problematic this mechanism is becomes really apparent when combined with the narrowing of Crocs’ materials target.  

In 2025, Crocs continued to rely on mass balance accounting and reported achieving 25.8% bio-circular content on a mass balance basis in its Classic Clog. On the surface, this looks like sustained progress: the same amount of investment in “bio-circular” credits, even if they don’t necessarily translate to actual bio-circular material in the shoes. However, the use of mass balance here doesn’t just make the shoes look greener than they are — it also allows Crocs to sneakily reduce its overall investment in bio-circular materials without looking like it did. 

Because mass balance credits can be allocated across products, Crocs can reduce the amount of bio-circular material it purchases — as it acknowledges happened in 2025 — while concentrating available credits onto a single flagship product line. This allows the brand to maintain the headline figure of roughly 25% bio-circular content and present continuity, even while overall use of bio-circular materials declines and emissions from Croslite™ compounds increase. In this way, mass balance is effectively helping preserve the appearance of consistency and even progress without requiring the company to increase investment in actually scaling real life low-carbon materials. 

If companies can reduce spending on low-carbon inputs while maintaining claims on low-carbon content through accounting credits alone, it becomes difficult to argue that these systems are driving the scale-up of alternative materials that climate transition efforts are intended to achieve. 

As long as Crocs relies on accounting mechanisms alone to make materials claims, its climate progress will remain questionable at best. 

3. The system rewards this: how SBTi incentivises questionable target design and methodologies

Crocs picked its biggest-selling product, pointed all the credits and targets at it, and now looks better on paper while spending less in reality. The reasons behind Crocs’ strategic shift are likely multiple. However, the system it operates in, and specifically the role of voluntary standard setters such as the Science Based Targets initiative (SBTi) deserves closer scrutiny. 

In May 2025, shortly after releasing its 2024 sustainability report, Crocs received SBTi approval for a new climate target: “Reduce Scope 3 (Category 1 and Category 4) emissions by 58.2% per USD value added by 2032 from a 2022 base year.”

This target uses SBTi’s Greenhouse Gas Emissions per Unit of Value Added (GEVA) methodology. Unlike an absolute emissions reduction target, GEVA incentivises companies to prioritise methods that deliver the greatest emissions reductions relative to business value generated. 

For Crocs, the most commercially important product is the Classic Clog. It is both the company’s flagship product and one of its highest-volume revenue drivers. 

Against this backdrop, Crocs’ decision to narrow its materials target specifically to the Classic Clog makes sense. Concentrating bio-circular credits and materials investments on this product line specifically allows the company to:

  • Improve performance against its SBTi-approved Scope 3 target
  • Accelerate progress toward its existing Classic Clog carbon footprint goals (since 2022, Crocs has had a target of reducing this by 50% by 2030). 
  • All while reducing overall investment in bio-circular materials across the wider business 

In other words, Crocs’ strategy is to maximise what it can claim within existing reporting frameworks while minimising the scale of real-world investment required. 


This calls into question: to what extent do current target-setting and emissions reporting methodologies create incentives that support genuine decarbonisation, versus simply rewarding optimisation? 

The purpose of corporate climate action is not simply to produce lower numbers on sustainability scorecards. It is to accelerate the real-world transition away from fossil fuels and toward genuine decarbonisation solutions. That transition requires investment. It requires profit-reaping companies to help scale emerging solutions, create demand for low-carbon materials, and contribute to building the markets needed for systemic change. 

If Crocs can reduce investment in bio-circular materials while maintaining claims of progress through accounting mechanisms and target design, it is fair to ask whether the system is delivering the outcomes it was intended to achieve. 

This is why scrutiny of standard-setting bodies and emissions reporting frameworks matters. The rules create the environment in which companies can either be ambitious and focus on genuine decarbonisation, or find comfortable loopholes that can carefully be packaged as progress and ambition, while being the exact opposite of progress and ambition. 

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