With an increased consumer demand for businesses to showcase sustainability credentials, it is important that any claims made on-pack comply with the UK Government’s Green Claims Code. This guidance published September 2021 and those who fail to comply with it may be financially penalised by the Competition and Markets Authority.
We lay out the six guidelines in this blog. The information provided is sourced from the UK Gov website:
1. Claims are truthful and accurate
Businesses must live up to all claims made. Businesses may be tempted to use broad, general terms – like ‘green’ or ‘eco-friendly’ – in their environmental claims. One concern with them is that their meaning can be unclear. Such claims also risk misleading consumers by creating a much more favourable impression of a product’s, service’s, process’s, brand’s or business’s environmental credentials than is justified. That, of course, may be the attraction for a business to use them. Businesses contemplating making these kinds of broad and absolute claims should consider whether they have clear evidence that their products, services, processes, brands and activities have a positive environmental impact (or no negative one). Without it, such claims are much more likely to mislead consumers.
2. Claims are clear and unambiguous
A customer should be able to understand the claims that you are making! The terms used in a claim, and the meaning they convey to consumers, should be clear. The meaning consumers are likely to take from a claim and the environmental credentials and impacts of the product, service, process, brand or business should match. Vague and/or general statements of environmental benefit are more likely to be misleading. At best, they can have a number of meanings that can confuse consumers and make it difficult for them to make informed decisions. At worst, they can give the impression a product, service, process, brand or business is better for the environment than is really the case. They can also be difficult to substantiate
3. Claims do not omit or hide important information
Be sure that claims made do not omit or hide information. Consumers can be misled where claims do not say anything about environmental impacts. This can also happen where claims focus on just one aspect of a product, service, brand or business. They can be misleading because of what they do not include or what they hide. Claims should not just focus on the positive environmental aspects of a product, service, process, brand or business, where other aspects have a negative impact and consumers could be misled. This is especially so if the benefits claimed only relate to a relatively minor aspect of a product or service or part of a brand’s or a business’s products and activities. Cherry-picking information like this is likely to make consumers think a product, service, process, brand or business as a whole is greener than it really is. It will be important for businesses to think about the claim they are making and the whole life cycle of the relevant product. Where they are promoting a brand or business, they should consider the impact of all its activities. They will also need to think about what consumers are likely to understand about the product, service, brand or business and about the claims that are made.
4. Claims compare goods or services in a fair and meaningful way
Products being compared should meet the same needs or be intended for the same purpose. Comparisons should enable consumers to make informed choices about competing products and businesses or between different versions of the same product. They should not say or imply, through the use of language or imagery, that one product (or one version of a product) is, for example, ‘greener’ or ‘environmentally friendlier’ or ‘more energy efficient’ than another, if it is not.
Businesses may make claims comparing their products with identifiable competitors’ or making comparisons between aspects of their own products (like old and new versions). Either way, the same considerations apply.
- any products compared should meet the same needs or be intended for the same purpose, with a sufficient degree of interchangeability;
- the comparison should be between important, verifiable and representative features or aspects of the relevant products; and
- the basis of the comparison, and the way it is presented, should allow consumers to make an informed decision about the relevant merits of one product over another.
5. Claims must be substantiated
Any claims made should be substantiated and backed up with robust and credible evidence. When considering making environmental claims, businesses should always consider the effect of the total life cycle of a product or service, or of their overall activities, on the accuracy of their claims.
This does not mean that information about the full life cycle of a product or service must be included in every claim. However, consumers are increasingly aware of, and concerned about, the impact on the environment of what they buy. This includes the impact of individual components or ingredients, and the stages of the production or disposal of a product. Businesses should therefore consider what elements of the life cycle of a product or service are most likely to be of interest to consumers when making an environmental claim and how they affect the accuracy of that claim.
Claims may be based on a specific part of an advertised product’s life cycle, or part of a business’s activities. It should be clear which aspect they refer to. They should not mislead consumers about the total environmental impact. A claim could itself be true, but misleading, if it suggests a product is greener than it is by ignoring some other aspect of its life cycle. Claims should also make clear the limits of any life cycle assessment the business has done.
6. Claims consider the full life cycle of a product
When considering making environmental claims, businesses should always consider the effect of the total life cycle of a product or service, or of their overall activities, on the accuracy of their claims.
This does not mean that information about the full life cycle of a product or service must be included in every claim. However, consumers are increasingly aware of, and concerned about, the impact on the environment of what they buy. This includes the impact of individual components or ingredients, and the stages of the production or disposal of a product. Businesses should therefore consider what elements of the life cycle of a product or service are most likely to be of interest to consumers when making an environmental claim and how they affect the accuracy of that claim.
At Benchmark, we believe that this is a step in the right direction towards standardising sustainability claims. It is important that businesses comply with these guidelines to enable consumers the option to make informed decisions, reducing their environmental impact in doing so.
Benchmark’s Carbon Calculator software allows businesses to comply with the Green Claims Code.
Contact us today to see how we can help your business reduce carbon emissions with your packaging supply chain and provide an independent on-pack, traffic light-coded, carbon label to truthfully showcase green credentials to your customers.
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