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The Ethics of Climate Nudges: Central Issues for
Applying Choice Architecture Interventions to
Climate Policy
Helena SIIPI*
and Polaris KOI**
While nudging has garnered plenty of interdisciplinary attention, the ethics of applying it to
climate policy has been little discussed. However, not all ethical considerations surrounding
nudging are straightforward to apply to climate nudges. In this article, we overview the state
of the debate on the ethics of nudging and highlight themes that are either specific to or
particularly important for climate nudges. These include: the justification of nudges that are
not self-regarding; how to account for climate change denialists; transparency; knowing the
right or best behaviours; justice concerns; and whether the efficacy of nudges is sufficient
for nudges to be justified as a response to the climate crisis. We conclude that climate
nudges raise distinct ethical questions that ought to be considered in developing climate nudges.
I. INTRODUCTION
Non-coercive interventions on choice architectures, commonly referred to as “nudges”, aim
to tweak the circumstances in which decisions are made in order to improve decision
outcomes. While nudges remain controversial, they are also the subject of much
enthusiasm as a “soft” means to steer citizens without having to resort to “hard”
regulations. Nudges have been suggested or carried out in various fields of life including
healthy eating,1 physical activity,2 retirement saving,3 organ donation4 and charitable giving.5
*
Department of Philosophy, Contemporary History and Political Science, University of Turku, Finland;
email: helsii@utu.fi. This contribution was written in the context of a research project that received funding from
the Strategic Research Council at the Academy of Finland (grant number 335186).
**
Department of Philosophy, Contemporary History and Political Science, University of Turku, Finland;
email: polaris.koi@utu.fi.
1
R Cadario and P Chandon, “Which healthy eating nudges work best?” (2020) 39 Marketing Science 465.
2
Y Lin, M Osman and R Ashcroft, “Nudge: concept, effectiveness, and ethics” (2017) 39 Basic and Applied Social
Psychology 293.
3
CR Sunstein and RR Thaler, “Libertarian paternalism is not an oxymoron” (2003) 70 The University of Chicago
Law Review 1159.
4
B Engelen, “Ethical criteria for health-promoting nudges: a case-by-case analysis” (2019) 19 American Journal of
Bioethics 48, 49.
5
J Hobbs, “Nudging charitable giving: the ethics of nudge in international poverty reduction” (2017) 10 Ethics &
Global Politics 37.
European Journal of Risk Regulation (2021), page 1 of 18
doi:10.1017/err.2021.49
© The Author(s), 2021. Published by Cambridge University Press. This is an Open Access article, distributed under the terms
of the Creative Commons Attribution licence (https://creativecommons.org/licenses/by/4.0/), which permits unrestricted
re-use, distribution, and reproduction in any medium, provided the original work is properly cited.
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In this paper, the focus is on what we term “climate nudges”. A climate nudge is any
intentional modification of the choice architecture that aims to alter citizen behaviour
towards climate-friendly actions while maintaining their earlier alternatives. For
climate nudges, they both (1) encourage ways of behaviour that contribute to
mitigating climate change and (2) are motivated by climate concerns. Requirement
(1) limits climate nudges to ones that (according to the best available evidence)
enhance behaviour that is good for the climate. Thus, a nudge to plant trees can be a
climate nudge whereas a nudge to clear cut a forest is not one. Requirement (2) limits
climate nudges to ones that are carried out in order to enhance the state of the climate.
Thus, a nudge for bicycling to work, for example, is a climate nudge if it is carried out
for climate reasons and fails to be one if it is done in order to benefit the health of the
nudgees (even though it may factually contribute also to climate actions). Requirement
(2) does not limit climate nudges to ones that are motivated solely by climate concerns.
A climate nudge may well – in addition to climate concerns – also have other
motivations behind it.
Even though nudges aimed at enhancing environmentally responsible behaviour have
been designed,6,7,8 to date, ethical discussion concerning the use of nudges for climate
change mitigation purposes has been sparse.9,10,11 In what follows, we spell out
ethical topics that are to some extent specific to climate nudges. We consider an
ethical factor specific to climate nudges when there is either an ethically relevant
disanalogy between climate nudges and nudges in other contexts or when the ethical
factor concerns most climate nudges and is less central in other contexts of nudging.
We pool together ethical considerations that are specific to climate nudges as a
starting point for further academic discussion of climate nudges and as a tool for their
ethical assessment. However, this paper does not provide an exhaustive list that
would cover all ethical issues relevant to climate nudges. There are many ethical
issues that are relevant to all nudges that are not discussed in this paper. One example
of such a question is whether nudges retain the freedom and autonomy of the
nudgees.12,13,14 In addition, some ethical questions may arise only with respect to
very few climate nudges and still be crucial for the ethical assessment of those
particular nudges.
6
RH Thaler and CR Sunstein, Nudge: Improving Decisions about Health, Wealth, and Happiness (New Haven, CT,
Yale University Press 2008) p 185.
7
JL Roberts, “Nudge-proof: distributive justice and the ethics of nudging” (2018) 116 Michigan Law Review 1045,
1063.
8
PG Hansen and AM Jespersen, “Nudge and the manipulation of choice: a framework for the responsible use of the
nudge approach to behaviour change in public policy” (2013) 4 European Journal of Risk Regulation 3.
9
D Hilton, N Treich, G Lazzara and P Tendil, “Designing effective nudges that satisfy ethical constraints: the case of
environmentally responsible behaviour” (2018) 17 Mind & Society 27.
10
H Gehlbach, CD Robinson and CC Vriesema, “Leveraging cognitive consistency to nudge conservative climate
change beliefs” (2019) 61 Journal of Environmental Psychology 134.
11
JI Hukkinen, “Addressing the practical and ethical issues of nudging in environmental policy” (2016) 25
Environmental Values 329.
12
Hansen and Jespersen, supra, note 8.
13
T Grüne-Yanoff and R Hertwig, “Nudge versus boost: how coherent are policy and theory?” (2016) 26 Minds &
Machines 149.
14
DM Hausman and B Welsch, “Debate: to nudge or not to nudge” (2010) 18 Journal of Political Philosophy 123.
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The Ethics of Climate Nudges
II. THE NEED FOR THE
3
ETHICS OF CLIMATE NUDGES
Nudges raise promises in terms of guiding people towards more climate-friendly
behaviour. The term “green gap” refers to the disparity between a person’s positive
attitudes towards climate actions and their actual behaviour. The width of this gap has
been reported in several studies.15 Nilsen et al recommend nudges as an efficient tool
for narrowing this gap – especially in the contexts or energy consumption and waste
management.16 Sunstein suggests default nudges for decreasing emissions, such as an
opt-out method for airline passenger CO2 compensation fees.17 Together with Reisch,
he reports success in defaults on “print on both sides” for printers and for customer
selection of green energy.18
Discussion on the philosophical ethics of climate nudges remains scarce. This may be
taken to indicate that ethical discussion of climate nudges specifically is viewed as
unnecessary since the general discussion on the ethics of nudging is easily applicable
to them. This view can be challenged as various scholars have proposed the ethics of
nudging to be somehow context specific. Holm, for example, argues against nudging
in the clinical context but is ready to accept it in other areas of life:
Nudging in the clinical context raises specific issues that are distinct from the issues
raised by nudging in the public health or economic context and that entail that
nudging in the clinical context is almost always illegitimate.19
Holm is not alone in suggesting that nudging is not ethically problematic in general, but
only in particular contexts such as organ donation20,21 or informed consent in
healthcare.22,23 An extension of this acceptance of the relevance of the medical
context is to ask whether the context of climate policy also raises specific ethical
questions. In what follows, it is argued that climate nudges have ethically relevant
features that should be acknowledged in public decision-making related to climate
nudges. At least some of them may also raise further questions and require a more
detailed analysis than is provided in this paper.
15
G ElHaffar, F Durif and L Budé, “Towards closing the attitude–intention–behavior gap in green consumption: a
narrative review of the literature and an overview of future research directions” (2020) 275 Journal of Cleaner Production
122556.
16
ASE Nielsen, H Sand, P Sørensen, M Knutsson, P Martinsson, E Persson and C Wollbrant, Nudging and Proenvironmental Behavior (Copenhagen, TemaNord 2016) p 9.
17
CR Sunstein, “Nudges, agency, and abstraction: a reply to critics” (2015) 6 Review of Philosophy and Psychology
511, 515.
18
CR Sunstein and LA Reisch, “Green by default” (2013) 66 Kyklos 398, 399.
19
S Holm, “Context matters – why nudging in the clinical context is still different” (2019) 19 American Journal of
Bioethics 60, 60.
20
T Zuradzki and K Marchewka, “Organ donor registration policies and the wrongness of forcing people to think of
their own death” (2016) 16 American Journal of Bioethics 35.
21
For an opposing view, see PG Hansen, “Should we be ‘nudging’ for cadaveric organ donations?” (2012) 12
American Journal of Bioethics 46.
22
W Simkulet, “Informed consent and nudging” (2019) 33 Bioethics 169.
23
For an opposing view, see S Cohen, “Nudging and informed consent” (2013) 13 American Journal of Bioethics 3.
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Table 1. Ethical topics identified.
Ethical topics in published papers
Total
Freedom and/or autonomy
Consequentialist arguments
Concept of nudges
Personal values and preferences of nudgees
Responsibilities and rights of public authorities
Transparency
Inevitability of nudges
Comparison to other public-sector influences
Democratic/public decision-making
Nudges as a form of helping
Epistemic uncertainty
Human dignity
Comparison to private-sector influences
Self-regarding versus other-regarding nudges
Social context of nudging
Justice, fairness and/or equality
Consent
Vulnerable individuals and/or disadvantaged groups
Trust
Personal growth and/or learning
Public views
Privacy
Possibility of misuse
Concept of paternalism
Are nudges too inefficient?
Moral responsibilities of the nudgees
III. ETHICAL QUESTIONS DISCUSSED REGARDING
83
48
40
34
31
28
27
25
23
20
19
19
14
17
14
13
12
12
10
8
5
4
3
3
3
2
NUDGES
1. Method
In order to identify ethical questions central to climate nudges we conducted electronic
searches using Philosopher’s Index, Scopus and Web of Science. Surprisingly, only one
relevant paper was found through the combination of the terms “nudges or nudging and
climate and ethics”. The combination “nudges or nudging and environment and ethics”
received four hits. Since a reliance on previous scholarship on the ethical questions
relevant to climate nudges thus proved unfeasible, we instead first identified the
ethical questions central to all nudges in the literature and then analysed which of
these questions are especially central to climate nudges.
The search on terms “nudges or nudging and ethics” provided 159 publications on
Philosopher’s Index. Searches on Scopus and Web of Science (with the addition of
“philosophy” to the combination of terms) resulted in seven more papers. A total of
twenty-seven different general ethical topics were identified from these papers
(Table 1). These included, for example, the questions as to whether nudges are
freedom-retaining and when nudges need to be transparent. Moreover, twenty-three
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2021
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The Ethics of Climate Nudges
Table 2. Contexts of nudging identified.
Contexts of nudging in published papers
Healthcare (in general)
Food and eating
Organ donation
Informed consent in healthcare
Health insurance and/or retirement plans
Smoking
Accepting or refusing treatment
Clean living environment, avoiding rubbish/litter
Alcohol and other substance consumption
Traffic and transport
Environmental concerns (in general)
Vaccination
Drug (medicine) use
Physical exercise
Socially desirable and/or just behaviour
Climate actions
Energy consumption
Moral education
Sexual behaviour
Paying taxes
Elderly care
Gambling
Charity
Total
44
43
29
22
15
15
13
11
9
8
7
6
5
4
4
3
3
3
2
2
2
1
1
different contexts of nudging, such as organ donation and traffic, were identified
(Table 2). Many of the papers discussed several ethical topics and contexts. During
this process, thirty papers were excluded due to their non-relevance, being written in
a language other than English or non-availability, which left 129 papers for the full
analysis.
2. Results of the review
The most discussed ethical question (n = 83) was whether nudging compromises the
freedom or autonomy of the nudgees. The interest in this topic originates from
definitions. Originally, Thaler and Sunstein define nudges as “any aspect of the
choice architecture that alters people’s behaviour in a predictable way without
forbidding any options or significantly changing economic incentives”.24 Later, this
requirement has generalised into descriptions of nudges as freedom-retaining: nudges
are “interventions that steer people in particular directions but that also allow them to
go their own way. : : : To count as such, a nudge must fully preserve freedom of
choice”.25
24
25
Thaler and Sunstein, supra, note 6, p 6.
Sunstein, supra, note 17, p 511.
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The second most common ethical topic (n = 48) was consequentialist argumentation,
which weighs the possible and anticipated harms and benefits of nudging. Other
prevalent topics were the concept of nudge (n = 40), non-shared preferences (n = 34),
the rights and responsibilities of decision architects (n = 31), transparency (n = 28),
the inevitability of choice architecture (n = 27) and comparisons between nudges and
other steering methods in the public sector (n = 25). Some issues such as privacy and
possibilities for misuse were mentioned only in very few articles.
Unsurprisingly, the most discussed context of nudging was healthcare in general
(n = 44) followed by food and eating (n = 43). From the point of view of this paper,
it is interesting to note the small number of articles discussing environmental or
climate nudges. Eleven papers discussed clean living environments (often through
mentioning the “Don’t Mess with Texas” anti-littering campaign). Eight papers
included discussions of traffic, seven mentioned environmental concerns in general
and only three discussed climate actions and energy consumption.
3. Identifying novel issues and disanalogies relevant to climate nudges
Many of the above ethical issues can be resolved analogously in the climate context and
in other contexts. Existing analyses on whether nudges retain autonomy, for example, are
applicable to climate nudges. For some issues, however, the analogy either ceases or is
weakened. In what follows, we focus on aspects of nudge ethics that merit renewed
attention in the ethical analysis of climate nudges. While some of these aspects fall
within the range of popular topics in philosophical nudge ethics, the existing analyses
may not fully apply to climate nudges. We also highlight some aspects of nudge
ethics that have not received much attention but that are, in our view, particularly
important for the ethical assessment of climate nudges.
IV. SOME CENTRAL ETHICAL CONSIDERATIONS
FOR CLIMATE NUDGES
In this section, we highlight some ethical factors of climate nudges that strike us as
distinct from, or not fully analogous with, nudges in other contexts. Themes that are
general to all nudges fall outside the scope of this section unless the climate context
places particular emphasis on them or gives rise to disanalogies in their ethical
assessment.
1. Self-regarding nudges, other-regarding nudges and climate nudges
Nudge interventions are commonly justified by appeal to libertarian paternalism.
Libertarian paternalism is “an approach that preserves freedom of choice but
authorizes both private and public institutions to steer people in directions that will
promote their welfare”.26 Nudges are paternalistic when they constitute interference in
citizens’ lives in an effort to make them better off, and they are libertarian (in Thaler
26
RH Thaler and CR Sunstein, “Libertarian paternalism” (2003) 93 American Economic Review 175, 179.
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The Ethics of Climate Nudges
7
and Sunstein’s sense of the word) because they are non-coercive and preserve existing
options.
Most nudges aim to benefit the nudgee: these are termed self-regarding nudges in
M’hamdi et al.27 Typical examples are nudges related to health behaviours. Yet
nudging methods can also be used to create what M’hamdi et al term “otherregarding nudges”. Examples include nudges for organ donation28,29 and tax paying.30
The primary beneficiary of an other-regarding nudge is someone other than the
nudgee. Both self-regarding and other-regarding nudges may also have secondary
effects. Other-regarding nudges may result in secondary benefits that fall on the
nudgee: for example, nudges towards charitable giving may also result in improved
mood. Likewise, self-regarding nudges may have secondary other-regarding benefits.
Climate nudges are not self-regarding in the sense that they would primarily benefit
the nudgee. Thus, at first sight, they appear other-regarding. Yet the benefits form the
climate nudges fall on numerous people – including the nudgee and members of
future generations. Moreover, since climate change is connected to environmental
harm, the beneficiaries conceivably also include animals, plants, species and
ecosystems. Thus, in the case of climate nudges, the term “other-regarding nudge”
should either be understood very broadly or replaced with a new term such as “allregarding nudge”. The term “all-regarding nudge” may, however, be inaccurate in cases
where the costs of climate nudging for the nudgee are greater than gains they get from it.
The question of beneficiaries relates intimately to the ethics of nudging. The
justifications for self-regarding nudges are typically paternalistic. The justifications
for other-regarding nudges cannot be paternalistic, at least if paternalism is
understood as state interference justified by benefits to the person being interfered
with.31,32 Even if climate nudges are understood as all-regarding, the paternalistic
justification is insufficient. Rather, the justification must follow from the benefits to
other people, future generations and other living beings, or from other nonpaternalistic grounds. Hilton et al argue that “a law, tax or nudge that protects the
public by discouraging individuals from anti-social behaviour does not need to be
justified on paternalistic grounds. Instead they address a market failure”.33 For Hilton
et al, environmental nudges fit that bill. Likewise, Sunstein and Reisch suggest that
the justification of climate nudges could lie in externalities, in light of which nudges
aimed at reducing emissions could be justified on cost–benefit grounds.34
In summary, the justification of climate nudges does not flow easily from a standard
paternalistic standpoint. Rather, either flexibility needs to be introduced into the
27
HI M’hamdi, M Hilhorst, EAP Steegers and I de Beaufort, “Nudge me, help my baby: on other-regarding nudges”
(2017) 43 Journal of Medical Ethics 702.
28
A Sharif and G Moorlock, “Influencing relatives to respect donor autonomy: should we nudge families to consent
to organ donation?” (2018) 32 Bioethics 155.
29
Engelen, supra, note 4.
30
Sunstein, supra, note 17, p 514.
31
G Dworkin, “Paternalism” in EN Zalta (ed.), The Stanford Encyclopedia of Philosophy (Fall 2020 edition)
<https://plato.stanford.edu/archives/fall2020/entries/paternalism/> (last accessed 24 July 2021).
32
Hobbs, supra, note 5, p 39.
33
Hilton et al, supra, note 9, p 29.
34
Sunstein and Reisch, supra, note 18, p 401.
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conception of paternalism or climate nudges need to operate on a justification that is
categorically different from the libertarian paternalist justification of most nudges.
Examples of possible justifications that do not follow from libertarian paternalism include,
for example, utilitarian justifications and ones based on the rights of future generations.
2. Climate change denialists
Some climate change denialists deny the scientific consensus regarding anthropogenic
climate change. Others admit that global warming is taking place but oppose taking
action towards mitigating to it. These people should be accounted for in welldesigned climate nudging. Here, two concerns are relevant: that of nudging against
the will and values of some citizens and that of effectiveness.
Many hold that nudges should accord with the preferences of the nudgees – including
their normative standards.35,36,37,37 A citizen may object to being nudged either because
they do not want or value the objective of the nudge, such as in the case of climate change
denialists, or because while they want or value the objective of the nudge, they do not
wish to be nudged to behave accordingly.38 This latter, autonomy-based concern is
general to all nudges (and to almost any steering policy).
While many hold that nudges should accord with the values of nudgees, given
epistemic constraints on finding out the values of specific individuals, in practice
nudges operate on the level of a group of nudgees. For practical policymaking, the
relevant consideration therefore is that nudges should accord with the values that
are sufficiently prevalent within the population being nudged. The implication is that
the minority can make use of the other feature of nudges, namely that they are
option-preserving. Thus, at first sight, climate nudges do not differ from other nudges
in this respect (as long as the target population can reasonably be expected to consist
mainly of non-denialists). While climate change denialists may object to climate
nudges, this is not unlike, say, the dedicated carnivore’s opposition to nudges towards
vegetarian options. Recalling that nudges are not compelling, a climate nudge is a
nudge only if it allows for the denialist to keep acting according to their ideology.
This requirement of retaining the options is common to all nudges regardless of
whether they target health, wealth, climate or other features. However, acting
according to one’s ideology is possible only if one can distinguish which alternatives
accord with it; this challenge will be discussed in the next section.
As for effectiveness, the impact of climate change denialism is twofold. First,
denialism impacts the behaviour of the denialist. Second, it impacts the scope of
policies that are feasible. For the first sort of impact, climate change denialism does
not have a substantive effect on the carbon footprint of the individual: rather than
political or climate beliefs, the primary correlate of the carbon footprint is socioeconomic
35
W Glod, “How nudges often fail to treat people according to their own preferences” (2015) 41 Social Theory and
Practice 599.
36
D Scoccia, “Paternalisms and nudges” (2019) 35 Economics and Philosophy 79.
37 37
S Conly, Against Autonomy: Justifying Coercive Paternalism (Cambridge, Cambridge University Press 2013).
37
Engelen, supra, note 4, p 50.
38
See Glod, supra, note 35, p 604.
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9
status.39 In other words, attitudes towards climate actions have little direct effect on the carbon
footprint. Instead, the impact of denialism on behaviour is aversion towards climate matters,
and thus stating the intended climate benefit of the nudge may decrease its effectiveness in
steering denialist behaviour. This pragmatic consideration is in tension with the requirement
that it should be possible for nudgees to select among possible options based on their values.
This kind of tension concerns all nudges but is especially pressing regarding climate nudges
as they lack paternalistic justification.
Climate change denialists are a marginal but vocal group whose presence in public
discussions may hinder the public acceptance of various forms of climate policy, not just
climate nudges. For this reason, some believe denialists ought to be nudged to accept the
reality of global warming and the desirability of climate-friendly behaviour.40 However,
climate nudges targeting denialists specifically do not conform to the desideratum that
nudges should be aligned with the values of the nudgees. Yet when the aim is to alter
beliefs rather than behaviours specifically, this desideratum may in some cases cease to
be consistent. Levy suggests “nudging to reason” as an acceptable class of nudges that
would, if successful, make persons more sensitive to genuine evidence.41
Whether or not nudges to reason are a feasible possibility, a further workaround
remains: to avoid nudging denialists altogether and relying instead on changing the
status quo with the help of more willing participants. Computational models yield
some indication that a 25% minority norm has the potential to become the new
predominant norm of behaviour.42 If further studies confirm this, the collaboration of
denialists may not be necessary for creating climate-friendlier societal norms of
behaviour. When new societal norms are established, denialists will, in time, follow
suit in terms of behaviour.
3. Transparency
The transparency of nudges refers to so-called type interference transparency and token
interference transparency. Type interference transparency means that a government
informs citizens that it uses nudge methods but does not necessarily make it possible
for citizens to notice each nudge. Token interference transparency means that a
particular intervention can be easily identified as a nudge.43 Type interference
transparency is quite generally accepted as a necessary condition for ethically
acceptable nudging.44,45 This implies that other requirements – including token
39
S Moser and S Kleinhückelkotten, “Good intents, but low impacts: diverging importance of motivational and
socioeconomic determinants explaining pro-environmental behavior, energy use, and carbon footprint” (2018) 50
Environment and Behavior 626.
40
D Lenzi, “Deliberating about climate change: the case for ‘thinking and nudging’” (2019) 6 Moral Philosophy and
Politics 313.
41
N Levy, “Nudges in a post-truth world” (2017) 43 Journal of Medical Ethics 495.
42
D Centola, J Becker, D Brackbill and A Baronchelli, “Experimental evidence for tipping points in social
convention” (2018) 360 Science 1116.
43
L Bovens, “Ethics of nudge”, in T Grüne-Yanoff and SO Hansson (eds), Preference Change: Approaches from
Philosophy, Economics and Psychology (Berlin, Springer 2008) p 216.
44
AT Schmidt, “The power to nudge” (2017) 111 American Political Science Review 404.
45
Hansen and Jespersen, supra, note 8, p 17.
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interference transparency – may not need to be fulfilled in some instances of nudging, but
nudging cannot be ethical if it is not type interference transparent. This raises interesting
questions. Does the government need to inform citizens about the contexts, aims or
methods of nudging used? Or is it sufficient just to notify that it uses nudges without
specifying where, when and why nudges are used? These questions are analogous
with respect to climate nudges and other nudges.
Nudges are token interference transparent to different degrees. Verbal framing is often
quite opaque, while gamifying the environment is usually easy to notice.46 The degree of
transparency does not depend merely on the method chosen, but also on the nudgees and
their situation. An educated individual in a familiar environment and peaceful situation is
more prone to realise that they are being nudged than a less educated person who is
under stress in a foreign milieu.47 The degree of transparency of food arrangement
nudges, for example, depends on several factors, such as the information provided to the
nudgees, the methods of arrangement as well as the earlier experiences, current situation
and knowledge level of the customers.48,49
Whether, on what condition and to which extent nudges should be token interference
transparent has been discussed to some extent. Transparency enhances the feasibility of
selecting alternative options in case a nudge is against nudgees’ normative commitments.
However, it may also diminish the effectiveness of the nudge and thus diminish the
expected benefits.50,51,52 (Interestingly, transparency can also make some nudges more
efficient.53,54) The strictest ethical requirement regarding token transparency would
require that each nudgee is aware of being nudged at each occasion of nudging. In
practice, this would imply that every nudge must be accompanied by a clearly visible
notification that it is taking place. This kind of requirement is generally agreed to be
over-demanding as it would imply, for example, that gamified rubbish bins (meant to
promote recycling) or reorganised parking arrangements (which encourage the use of
environmentally friendly transportation) would only be acceptable if each nudgee were to
receive information about them. Rather, ethical nudging usually is seen to require in
principle token interference transparency or reasonable token interference transparency,
meaning that a watchful individual could, without unreasonable effort, notice that it is
taking place.55,56,57
46
Engelen, supra, note 4, p 54.
V Ivanković and B Engelen, “Nudging, transparency, and watchfulness” (2019) 45 Social Theory and Practice 43.
48
Sunstein, supra, note 17.
49
Hausman and Welsch, supra, note 14.
50
Bovens, supra, note 44, p 217.
51
T Grüne-Yanoff, “Old wine in new casks: libertarian paternalism still violates liberal principles” (2012) 38 Social
Choice and Welfare 635, 638.
52
Ivanković and Engelen, supra, note 48, p 43.
53
Schmidt, supra, note 45, p 406.
54
Ivanković and Engelen, supra, note 48, p 43.
55
ibid.
56
Bovens, supra, note 44.
57
Schmidt, supra, note 45.
47
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Transparency also raises special considerations regarding climate nudges. These
considerations relate to the distinction between transparency about means and
transparency about ends.58 Hansen and Jespersen tie these two together:
A transparent nudge is defined as a nudge provided in such a way that the intention
behind it, as well as the means by which behavioral change is pursued, could
reasonably be expected to be transparent to the agent being nudged as a result of
the intervention.59
Hansen and Jespersen take a nudge to be transparent when a watchful individual could,
without unreasonable effort, realise that they are being nudged to behave in the way W for
the reason R. A climate nudge is transparent in this sense, for example, when a nudgee can
easily notice that they are nudged towards cycling (instead of driving) in order enhance
the state of the climate. However, for many climate nudges, transparency regarding
means does not imply transparency regarding intentions.60 A nudgee may well realise
that they are being nudged towards cycling without gaining any information on why
someone wants them to increase their cycling behaviour. Furthermore, nudgees can
misinterpret the intentions behind nudging. Many climate nudges (eg nudges for
cycling or for reducing meat consumption) can easily be construed as health nudges.
When climate nudges encourage saving energy or other resources, they may be
misunderstood as nudges for financial prudence.
The possibility of misunderstandings is intimately connected to climate change
denialism. It was stated in the previous section that a climate nudge is a nudge only if
it allows the denialist to keep acting according to their ideology. The question is:
what degree of transparency regarding intentions suffices to preserve this sort of
freedom in climate nudging? For example, a citizen who might condone being
nudged to cycle for health purposes may strongly oppose being nudged to cycle for
climate reasons. In short, people may oppose being nudged to behave in a certain
way not only because of the overt behaviour itself, but also for the reasons why they
are being nudged towards that behaviour.61 However, when balanced with other
considerations, including the seriousness of the climate crisis (to be discussed in the
final section of this paper), it is not self-evident that intention-transparent climate
nudges are necessarily ethically superior to intention-opaque climate nudges. Rather,
the ethical acceptability and desirability of a climate nudge should be weighted from
the points of view of several factors addressed in this paper.
4. Knowing the right or best behaviours
All nudges presuppose judging some alternatives better than others. The classic “cafeteria
nudge”, for example, rests on the assumption that the manager can easily distinguish
58
59
60
61
Ivanković and Engelen, supra, note 48, p 53.
Hansen and Jespersen, supra, note 8, p 17.
Ivanković and Engelen, supra, note 48, p 53.
Ivanković and Engelen, supra, note 48.
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between healthy and non-healthy alternatives. As Lenzi points out, the presence of choice
architects who competently assess what sorts of behaviours to promote is often taken for
granted.62 However, rather than being specific to nudging, this presumption is general to
public policy where the assumption is that policymakers are (sufficiently) well placed to
make beneficent decisions. In democracies, policymakers are expected to justify their
choices concerning what sorts of behaviours are promoted. As discussed above, with
respect to nudges this justification is often verbalised as the requirement of type
interference transparency.63,64
However, for climate nudges as well as for any public climate policy aiming to steer the
general population, assessing which particular behaviours should be nudged towards can
sometimes be a challenge. Even though there is consensus on appropriate actions
regarding climate change in the broad sense (eg cutting greenhouse gas emissions)
and even though there is consensus that some habits are especially harmful to the
environment (eg flying and meat consumption), ideological reasons as well as the
complexity of the causal networks underlying climate change generate disagreement
concerning which changes to citizen behaviour are the most effective ones.
The challenges in identifying the most efficient and feasible climate actions are
increasingly ones that require complex and multifactorial cost–benefit and feasibility
assessments. Policymakers may, in the climate context specifically, be better placed
to choose the best behaviours than citizens are. As a result, nudging towards
particular climate-friendly actions rather than steering generally towards climatefriendliness may be preferable because citizens, attempting to decrease their impact
on the climate, may replace their existing behaviours with options that are in fact less
climate-friendly. For this reason, “boosts” or “nudges to reason” may not be the most
efficient choices in the context of climate nudges.65,66
However, even if policymakers are better placed to assess the actual climate impact of
various actions, this is not always a simple feat. For newer innovations particularly, the
long-term emissions from their production, care and how often they are replaced may be
subject to uncertainty. If there are more uncertainties regarding climate actions than there
are regarding, for example, health actions, then climate nudging includes more
uncertainties than health nudging, which places higher demands on the expertise of
choice architects for climate nudges. Climate nudging thus requires particular
diligence in nudging only towards behaviours that in fact are beneficial to the climate.
5. Justice
Ethical considerations surrounding climate nudges include both local and global justice.
The global justice questions arise from the fact that mitigating climate change implies
costs and burdens for societies and nation-states. How should these be divided?
62
Lenzi, supra, note 41, p 325.
Hansen and Jespersen, supra, note 8.
64
Schmidt, supra, note 45.
65
R Hertwig and T Grüne-Yanoff, “Nudging or boosting: steering or empowering good decisions” (2017) 12
Perspectives on Psychological Science 973.
66
Levy, supra, note 42.
63
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Several principles such as “The Polluter Pays”, “The Beneficiary Pays” and “The Ability
to Pay” have been suggested for global climate policy, but the questions about duties and
responsibilities remains open.67 When applied to nudging, the big question is which
governments have the strongest duty to significantly invest in nudging programmes
and to start to nudge their citizens towards more climate-friendly actions. The most
plausible answers likely accord with general global climate justice theories. No
feature of nudging implies that the burden of governments regarding it should be
distributed differently from the burdens entailed by other climate policies. However,
given that nudging methods are “soft”, additional questions arise: which (if any)
societies are entitled to prioritise nudging or to settle for it instead of stronger and
more efficient methods such as direct bans and restrictions? How should climate
nudging and more efficient (but also politically less appealing) methods be balanced?
For further discussion on whether nudges are sufficiently efficient, see the next section.
Questions of local justice concern the distribution of the costs and benefits of nudging
between individuals within the target population being nudged. While nudges should not
include significant economic incentives, there are many possible costs to climate nudges.
A nudge towards winter cycling in cold climates, for example, implies costs for the
nudgees who choose to comply with it. These may include the monetary cost of
winter tyres and appropriate clothing and the additional time used for transport (if
cycling implies giving up a faster means of transport), as well as possible accident
and health risks related to icy winter conditions. On the other hand, nudgees may also
benefit from climate nudging. In the case of winter cycling, the possible benefits
include secondary benefits such improved health resulting from the exercise and
enjoyment of riding a bicycle (one of the authors is among those who find cycling in
icy conditions enjoyable; the other author has the opposite disposition). Moreover,
intention-transparent nudges may diminish climate anxiety and bring about
psychosocial benefits related to experiences of togetherness, altruism and solidarity.
The questions about justice concern the distribution of these possible costs and the
benefits of making choices within a given target population, whether their choices
accord with the aims of the nudge or not.
Fowler and Roberts criticise nudging programmes for all too often assuming that
nudgees are a homogeneous group with equal access to the necessary resources to be
effectively nudged. According to them:
[N]ot all choices are equally available to everyone : : : [In cafeteria nudges, the]
clever placement of fruit and vegetables will not convince someone who simply
cannot afford [them] : : : The very nature of choice architecture as a policy
intervention assumes that people have access to meaningful choices.68,69
67
S Caney, “Climate justice” in EN Zalta (ed.), The Stanford Encyclopedia of Philosophy (Summer 2020 edition)
<https://plato.stanford.edu/archives/sum2020/entries/justice-climate/> (last accessed 28 July 2021).
68
LR Fowler and JL Roberts, “A nudge toward meaningful choice” (2019) 19 American Journal of Bioethics 76, 76.
69
For similar views, see also J-F Ménard, “A ‘nudge’ for public health ethics: libertarian paternalism as a framework
for ethical analysis of public health interventions?” (2010) 3 Public Health Ethics 229.
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Roberts argues that vulnerable populations and particularly the most disadvantaged
individuals are “nudge-proof” in certain contexts. No matter how well-designed the
nudges are, some individuals cannot enact the behaviours that the nudges are
designed to promote. For example, a nudge for physical exercise is hopelessly
inefficient when the nudgee lacks time, social support (eg a babysitter) and/or access
to a safe exercising environment.70 Returning to the climate nudge for winter cycling,
it seems unlikely that safe and comfortable winter cycling would be accessible to all
members of a given society. Thus, nudges may leave behind those in greatest need
and in the most vulnerable positions.71 This threat is most pressing regarding health
nudges and other self-regarding nudges. Yet this concern should also be
acknowledged in climate nudge design and development – especially when the
nudges used rely on enhancing social status, diminishing climate anxiety or building
positive experiences, such as a sense of togetherness, for the nudgees.72 On the other
side of the coin, some nudges (eg default options) work especially well on less welloff individuals.73,74
As noted above, the nudgees’ ability to notice nudges is situation sensitive.75 Thus,
nudges that are in principle token inference transparent may in practice be most
opaque to individuals who are – because of their history or current life situation – in
a vulnerable position. Since individuals are more prone to resist those nudges that
they notice, less well-off individuals may be more likely to enact the desired
behaviour. As a result, when choosing according to the aims of a nudge implies costs
(eg loss of time or loss of a pleasure), those costs may turn out to be paid by those
members of society who in the beginning had less. This possibility calls for extra
attention when designing other-regarding or all-regarding nudges such as climate
nudges. Moreover, as Roberts points out, nudges that imply only minimal costs to the
average citizen may be harmful for some of the more vulnerable citizens. As an
example, she discusses opt-out system for green energy. Less well-off individuals are
more likely to stay on the default. At the same time, they are the ones who suffer
most from buying the more expensive green energy. This example illustrates that
there sometimes are ethical rationales for using economic incentives (eg lowering the
price of the green energy) in conjunction with nudging.76
The justice concerns do not, as such, imply that climate nudges would be ethically
unacceptable or problematic. However, they are a factor that should be acknowledged
in nudge design and implementation and weighed together with other relevant factors
presented in this paper. Even though other morally relevant issues may sometimes
outweigh the unfairness of a particular nudge, it is also easy to accept that prima facie
just nudges should be preferred to ones that aggravate inequalities. Well-designed
70
Roberts, supra, note 7, p 1048.
Fowler and Roberts, supra, note 69.
72
Hobbs, supra, note 5.
73
CR Sunstein, Why Nudge? Politics of Libertarian Paternalism (New Haven, CT, Yale University Press 2014)
p 179.
74
Roberts, supra, note 7, p 1056.
75
Ivanković and Engelen, supra, note 48, p 53.
76
Roberts, supra, note 7, p 1056.
71
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nudges can also promote justice. Consequently, the allocation of the costs and benefits of
climate nudges should be a concern to policymakers and an integral part of good nudge
design.
6. Weighing the effectiveness of nudging against the seriousness
of the climate crisis
Finally, a central question regarding climate nudges is whether their effectiveness is
sufficient to justify them in a context as serious as the climate crisis is. Effectiveness
here refers to the changes in actual behaviour brought about by the nudge. The
challenge is that some nudges may score low in their effectiveness even though they
show high efficacy in controlled (laboratory) conditions.77 Mitigation of climate
change requires lasting changes in behaviour. The empirical question is whether
nudges are suitable for bringing about the required changes or whether some other
feasible methods are more effective – either as such or in relation to their costs.
Being relatively cheap to implement, nudges tend to score well in cost–benefit
analyses. The most efficient nudges, however, are based on the use of defaults (optout instead of opt-in) regarding decisions that are done only once or rarely.78 Default
nudges are less readily applicable to the climate context.79 The behavioural changes
required to mitigate climate change are long-lasting; however, the jury is still out
regarding the persistence of nudge effects after the nudge intervention is no longer
present. While nudging can yield short-term results, there is a risk of backsliding.80
The backsliding phenomenon refers to the behavioural impact of a policy “wearing
off” after a period of time. The body of longitudinal data on nudging continues to be
slim. Allcott and Rogers show that nudge effects decreased over time but did not
disappear entirely, whereas Ferraro et al demonstrate that a social comparison-based
setup produced effects that could still be detected two years after the intervention.81,82
Due to the small volume of longitudinal data, we should be cautious about the
generalisability of these promising data. Low confidence regarding the long-term
effects of nudging will continue to be justified until a larger body of research is available.
While the worry about sustained effects is general to many nudges, it is particularly
pressing for climate nudges given the gravity of the climate crisis: for some health
nudges, for example, we can consider short-term improvement a success, but given
the time sensitivity and catastrophic impacts of climate change, short-term
improvements may amount to futile exercises in the sphere of climate policy. At their
77
For further discussion, see E Ernst and MH Pittler, “Efficacy or effectiveness?” (2006) 260 Journal of Internal
Medicine 488.
78
For organ donation, see MU Ahmad, A Hanna, A-Z Mohamed, A Schlindwein, C Pley, I Bahner, R Mhaskar, GJ
Pettigrew and T Jarmi, “A systematic review of opt-out versus opt-in consent on deceased organ donation and
transplantation (2006–2016)” (2019) 43 World Journal of Surgery 3161.
79
JM Jachimowich, S Duncan, EU Weber and EJ Johnson, “When and why defaults influence decisions: a metaanalysis of default effects” (2019) 3 Behavioural Public Policy 159.
80
H Allcott and T Rogers, “The short-run and long-run effects of behavioral interventions: experimental evidence
from energy conservation” (2014) 104 American Economic Review 3003.
81
ibid.
82
PJ Ferraro, JJ Miranda and MK Price, “The persistence of treatment effects with norm-based policy instruments:
evidence from a randomized environmental policy experiment” (2011) 101 American Economic Review 318.
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worst, climate nudges and other minor improvements may postpone of hinder the
implementation of major, necessary changes as the minor improvements give people
the impression that they are already doing their share (or at least something).
Another effectiveness limitation of nudges is that they are behaviour specific (ie they
target a particular behaviour, such as mode of commuting or energy use, rather than
generating general changes towards sustainability across citizens’ behaviours). This
makes behavioural public policy vulnerable to the worries outlined in the previous
sections.
A further worry is that even if nudges were effective, they would be pedagogically
counterproductive. Bovens worries that nudges may be self-defeating in the long
term, as “[r]egulation as well as environmental cues to discourage or encourage
certain behaviour may leave the agent with a lack of moral strength to implement the
target behaviour once the regulation or the environmental cues are no longer
present”.83 Furedi goes even further in stating that nudge policies may erode citizens’
capacity to exercise judgment.84 Bovens and Furedi seem to believe that public policy
should not just steer towards the practical upshots of citizens’ choices, but rather
good policymaking involves moral pedagogy, and that nudging may fail to cultivate
citizens’ moral agency.85 However, as discussed above, some forms of nudging can
even enhance individuals’ morality and rationality.86,87 Yet the issue remains
speculative, as there are no longitudinal studies concerning the impact of nudges on
moral agency.
Additionally, it can be questioned whether any policy targeting citizen behaviour,
including nudging, is the correct response to the climate crisis. This is because nearly
two-thirds of global carbon emissions can be traced back to ninety industrial
corporations.88 Are citizens the entities that need to change their behaviour to
mitigate climate change, or should regulation that targets the private sector instead be
prioritised? Whether opponents of stricter regulation of the private sector are correct
in arguing that this would have adverse effects on the economy, it may be that in the
face of corporate lobbying and other effects on public policy that slow down
regulation of the private sector, nudging citizens remains a viable climate policy not
because it is the best imaginable policy but because it can be done.
Given the gravity of the climate crisis, it may be objected that nudges are unacceptable
simply because they are a soft form of policy: serious matters that are a threat to the
ecosystem and to human life should call for stricter policy. Here, of course, nudging
can also be used to supplement strict policy: no climate policy should consist solely
in nudging but, instead, a combination of soft and hard policy should be used, and
83
L Bovens, “Real nudge” (2012) 1 European Journal of Risk Regulation 43, 44.
F Furedi, “Defending moral autonomy against the army of nudgers” (Spiked, 2011) <https://www.spiked-online.
com/2011/01/20/defending-moral-autonomy-against-an-army-of-nudgers/> (last accessed 20 August 2021).
85
For further discussion, see Hobbs, supra, note 5.
86
AT Schmidt and B Engelen, “The ethics of nudging: an overview” (2019) 15 Philosophy Compass 4, 5.
87
Levy, supra, note 42.
88
B Ekwurzel, J Boneham, MW Dalton, R Heede, RJ Mera, MR Allen and PC Frumhoff, “The rise in global
atmospheric CO2, surface temperature, and sea level from emissions traced to major carbon producers” (2017) 144
Climatic Change 579.
84
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soft policy can also be used to ensure compliance with regulations. The ethical question
for any climate action designer is the weighting of different methods. If nudges alone are
not sufficient, do they add value to other methods? If yes, how should the different
methods be weighted in policy solutions and in the prioritisation of policymakers’
resources?
V. CONCLUSION
The aim of this paper has been to discuss disanalogies between climate nudges and
nudges in other contexts, as well as to provide an overview of some central ethical
considerations in the development of climate nudges. We have spelled out six
morally relevant features of climate nudges – that is, features that need to be taken
into account in designing them. These include the justification of nudges that are not
self-regarding; accounting for climate change denialists; transparency; knowing the
right or best behaviours; justice concerns; and whether nudges are sufficiently
efficient and reliable to be justified as a form of climate policy.
We argue that the ethical assessment of climate nudges needs to be pluralistic in the
sense of taking into account all of these six factors, as well as factors that concern all
nudges (eg questions regarding freedom). All of these factors are prima facie in
character. The prima facie character of an ethical factor means that a climate nudge
should accord with it unless another – on that occasion stronger and more important –
factor trumps it.89,90 Ethical considerations, including the ones discussed in this paper,
in practice often are in friction with each other. For instance, improving the
transparency of a climate nudge may decrease its effectiveness. Likewise, duly
accounting for climate denialists may sometimes stand in friction with global justice
considerations. As a result, the ethical assessment of nudges involves weighing the
ethically relevant factors against each other.
The presented type of understanding of ethical assessment and decision-making
seldom (if ever) rests on a static view regarding the strength and importance of
different ethically relevant factors. Rather, the prioritisation of different ethical
considerations is situation sensitive.91 As a result, the ethical assessment of climate
nudges includes three stages: (1) spelling out any morally relevant considerations
(including the ones listed in this paper); (2) analysing whether the proposed nudge
accords with these factors; and (3) justification of any deviation from these factors. In
this final stage, any conflicts between the ethical factors are analysed, and the
prioritisation of some considerations over others is justified by referring to which
ethical factors are the most important in that particular situation. Since the practical
conflicts between the relevant factors are common, the central outcome of the ethical
89
M DePaul and A Hicks, “A priorism in moral epistemology” in EN Zalta (ed.), The Stanford Encyclopedia of
Philosophy (Summer 2021 Edition) <https://plato.stanford.edu/archives/sum2021/entries/moral-epistemology-apriori/> (last accessed 20 August 2021).
90
JF Childress, “A principle-based approach” in H Kuhse and P Singer (eds), Companion to Bioethics (Hoboken, NJ,
Blackwell Publishers 2001).
91
ibid.
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assessment of climate nudges typically involves the situation-specific justification of
prioritising some ethical considerations over others.
In this paper, our aim has not been to argue that climate nudges are morally more
problematic than other nudges. On the contrary, we believe that climate nudges may
provide an effective and interesting tool for enhancing climate-friendly behaviour.
However, acknowledging the ethical questions that climate nudges raise should be
included in their design.