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Environmental Claims Consultants 

If you aim to publish environmental claims about you product or service, we can help you check you are meeting the relevant guides, and keep you on the right side of the law. Additional to the legal "incentive" it is worth considering that consumers are becoming ever more informed, and a meaningful environmental claims will be a good thing for your product or service.

In September 2021 the Competition & Markets Authority released there guidance on what constitutes a fair environmental claim. The guidance covers the display of environmental claims on Goods and Services. If you would like help checking that you meet the criteria set out in the guide, then please get in touch.

This move is doubtless to clarify what is expected of an environmental claim, often displayed as green labels on items. These environmental claims can cover all sorts of topics:

There are many environmental claims made over the last decade or so that have been shown to be false and misleading. Various Tuna Brands have labeled there product as Dolphin Safe, when in fact they have no way of proving that it is. Case study: StarKist Tuna.

Other labels are placed on packaging with little thought to their accuracy or usefulness. Some labels (constituting an environmental claim) are used impulsively. One such example is the ubiquitous recycling loop.recycle loop environmental claim Which has been on products for decades.







But with the release of new guidance from Competition & Markets Authority, will this type of environmental claim still be considered legal? Let us check the recycle loop logo against the criteria as listed in the guide:

Environmental Claims must be Truthful and Accurate

Using the green recycle loop label as above, we could fall foul of the new guidelines if the label was placed on materials that was not recyclable. For example if this was printed on the back of a packaged toy, where the elements of packaging were made from type 7 plastics. One option here might be to break down the various materials, and give instructions, such as this Australian Label below.


Environmental Claims must be Clear and Unambiguous

Unambiguous (not open to more than one interpretation). This symbol has been widely misunderstood in the past, with consumers perhaps thinking it means that the product or packaging is made with recycled materials. But for the most part it means recyclable. So under the new guide it will be required that clarification is given.

smart water 100%








Adding the text "recycled or recyclable" may well help meet this part of the guidance. But in truth, at this point (in terms of details) we are likely leaving the realm of labels, and heading towards infographics or adverts inset.

Creative Commons Licensed credit Jaggery

Environmental Claims must Not Omit or Hide Important Relevant Information

With such a simple logo as the recycling loop above, nearly all relevant information is omitted. This part of the guidance we can assume refers to written claims. For example here we might consider a bottle water company that switches from plastic to aluminum bottles, in an attempt to be "environmental friendly".

This move will reduce plastic waste by 100%. But what about other impacts. Aluminum is a energy hungry metal to produce, can it be recycle easily. Making the claim that aluminum water bottle are environmentally friendly may have to be backed up with information showing that these other factors have been considered, as they could be considered relevant information.

Comparisons must be Fair and Meaningful

Using the example of the bottled water above. If you planned to label water as carbon neutral, it would have to be done in way that made it comparable with other environmental claims of that type.

Standards such as PAS2060 show how to footprint a product. If you were to claim a bottle of water is carbon neutral then you have to measure & eliminate Scope 1,  Scope 2 and Scope 3 emissions as a minimum.

Claims must Consider the Full Life Cycle of the Product or Service

This is likely best explained with examples:

Example 1 - Carbon Neutrality - A bottle water supplier would like to become carbon neutral. They buy bottles from a bottle manufacturer, print their own labels, and fill the bottled, prior to boxing and dispatch. In this instance they could count Scope 1 and 2 emissions to give a company footprint that would not include emissions from manufacture of bottles, or the material the label is made out of. Under PAS2060 you can claim neutrality for a company based on Scope 1 and 2 emissions. But you could not claim that you product is Carbon Neutral. For this to be the case you would need to add Scope 3 Emissions for bottle manufacture, label and water, and then reduce or offset these emissions to zero.

Example 2 - Dolphin Friendly Tuna - A canning plant that owns no sea going vessels, buys whole tuna on the open market, and then cans and distributes the tuna. The company cannot put a Dolphin Friendly badge on the cans. It may not harm any Dolphins during the canning process, but it must investigate the supply chain fully prior to placing such an environmental claim on the packaging.

Claims must be Substantiated

For carbon neutrality you would need a report detailing the footnoting work undertaken to provide you baseline carbon footprint. These figure may need to be audited. If you are using carbon offsets you will need details of the offsets, including certificate numbers, relative to the scheme used REDD+, VSC or Woodland Carbon Code for example. 

For a good example of reporting please see Google's 2021 Environmental Report. This report contains details figures, year on year data for comparison (indicating repeatability) and links to audit reports, and specific projects that are used fro offset.