Consumer Products: Green Claims Code
- Green Claims Code (78 KB)
This code sets out the standard of information that the public can expect to be given about the environmental impacts of consumer products. The Government first launched the code in 1998, following wide consultation with business, consumer and environmental organisations. It has now been updated to take account of the new international standard on environmental claims, ISO 14021, which has been developed by standards bodies around the world.
The code is an introduction to the main issues, but businesses wishing to make environmental claims about their products are strongly advised to make use of the international standard. This gives more detailed guidance on statements, symbols, descriptions and verification appearing on product labels or in product literature and advertising.
This code is supported by the following organisations:
- Confederation of British Industry
- British Retail Consortium
- Local Authorities Coordinating Body on Food and Trading Standards
- British Standards Institution
Benefits for consumers
- expect that the environmental information they are given is accurate and helpful;
- question the meaning and relevance of claims they are not sure about;
- point to the international standard as the recognised benchmark of good practice, if they believe a claim is unclear; and
- if they are not satisfied, base their complaint in terms that are now commonly accepted.
Benefits for business
Responsible businesses, wanting to give environmental information about their products, will find that it is in their best interests to follow this code and to use the detailed guidance in ISO 14021. By following best practice in this field and giving clear, straightforward information, a business can:
- strengthen its reputation and credibility with consumers and with other business partners;
- demonstrate to regulators that it is trying to act responsibly, thus raising overall standards;
- meet requirements that may be introduced in some overseas markets.
What is a green claim
A 'claim' is information appearing on a product, its packaging, or in related literature or advertising material, which can be taken as saying something about its environmental aspects. It can take the form of text, symbols, or graphics.
A straight piece of advice to consumers of the product - for example, about care in its use or disposal - is not regarded as a claim. But such advice should still give consumers relevant information on which they can realistically act.
More general claims about the nature of the business offering the product are covered in separate guidelines on 'non-advertising' claims, issued by the Department of Trade and Industry. Some claims have their own specific legal frameworks. In particular:
- Foodstuffs, pharmaceuticals and hazardous materials already have their own legal requirements for labelling. However, the code does cover environmental claims which have been voluntarily applied to these products.
- Use of the official EU ecolabel and energy label is governed by specific regulations.
A GREEN CLAIM SHOULD BE ...
- Truthful, accurate, and able to be substantiated.
Businesses can be more certain of meeting these general principles of fairness in advertising and trade descriptions if they observe the other principles covered in this code. The ISO standard provides further information on how the detail can be got right in practice. There is no requirement for a business to get an independent verifier to check a claim before it is made. But it is prudent to be sure, in advance, that the claim would be truthful and accurate, and that it could be substantiated. ISO 14021 goes through the recommended steps to take. These include:
- checking that the claim is fair and truthful, whether by testing the product or otherwise;
- keeping adequate records of these checks;
- being prepared to give the relevant information to anyone who asks for the claim to be substantiated. (If the information is too confidential to disclose, it's unwise to make a claim.)
- Relevant to the product in question and the environmental issues
connected with it.
For example, a fair claim could be that 'this paper comprises 75% post-consumer waste'. On the other hand, it would be misleading to claim that it 'contains no tropical hardwood', as this is not a material used in making paper.
- Clear about what environmental issue or aspect of the product
the claim refers to.
For example, environmental information about the packaging of a product - such as its recycled content - can be relevant and helpful. But it would be misleading to give the impression that the product as a whole was 'recycled', if that was not the case.
- Explicit about the meaning of any symbol used in the claim
- unless the symbol is required by law, or is backed up by regulations
or standards, or is part of an independent certification scheme.
The use by a company of its own 'green' symbol or logo to give some form of reassurance to consumers is potentially misleading unless it is accompanied by a clear statement, in line with the Code, of just what the image means.
The Möbius loop should only be used for claims of recyclability and recycled content. Where it is used for claims of recycled content, the percentage of recycled content should be clearly stated.
- In plain language and in line with standard definitions.
The international standard ISO 14021 provides detailed guidance on the use of several terms which commonly appear in environmental claims. Businesses wishing to use these terms are strongly recommended to follow that guidance.
For instance, a claim that a product is 'biodegradable' should only be made if it would be true in the circumstances in which the product was likely to be disposed of, and if no substances were released in concentrations harmful to the environment. So, for example, it would be misleading to claim that a refuse sack was 'biodegradable' if it would first have to be separated from the waste it contained.
Other terms covered in ISO 14021 are:
- designed for disassembly
- extended life product
- recovered energy
- recycled content
- reduced energy consumption
- reduced resource use
- reduced water consumption
- reusable and refillable
- waste reduction
A GREEN CLAIM SHOULD NOT ...
- Be vague or ambiguous, for instance by simply trying to give
a good impression about general concern for the environment.
Claims should always avoid the vague use of terms such as 'sustainable', 'green', 'non-polluting' and so on. Likewise, they should avoid linking vague descriptions, such as 'friendly' or 'kind', with words like 'earth', 'nature', 'environment', 'eco' and 'ozone'.
Symbols should not feature natural objects such as trees, flowers, butterflies, or globes, unless there is a direct link between the product, the object and the environmental benefit being claimed. This link should be clearly explained.
- Imply that it commands universal acceptance if there is actually
some significant doubt or division of scientific opinion over the issue
- Imply more than it actually covers, if the claim is only about
limited aspects of a product or its production, or does not deal with
a significant issue for that type of product.
To take a technical example, it would be misleading to claim that a product is 'made with a chlorine-free whitening process' if that process, while free from elemental chlorine, still involved the use of chlorine compounds.
More generally, care should be taken not to concentrate on something which is literally true about a product, but which misses the main issue. For example, it may be literally true to say that a product is 'recyclable' - most products are, in theory! But in any case, if the main environmental issues about a particular product are not to do with its disposal or recycling, but with its manufacture or its effects in use, it is those issues which a good claim should try to address.
- Make comparisons, unless the comparison is relevant, clear
For example, it would be wrong to claim that a product is 'now even better for the environment', or 'uses less energy', without further qualification. But it could be fair to say that the product 'uses 20% less electricity in normal use than our previous model'.
- Imply that a product or service is exceptional if the claim
is based on what is standard practice anyway.
For example, it is unhelpful to claim that a product is biodegradable, if all products used for that purpose share that characteristic.
Equally, it is misleading to claim credit for a product not containing a particular harmful substance, if no products of that kind on the market actually contain it any more - or if they are legally forbidden to contain it. One such example is lead in paints, which has been banned in the UK since the 1970s. In this case, it would be more helpful to provide advice for consumers about stripping old paintwork, which might contain lead.
- Use language that exaggerates the advantages of the environmental
feature the claim refers to.
For example, it is misleading to say 'contains twice as much recycled content than before', if the original amount of recycled material was very small.
- Imply that the product or service is endorsed or certified
by another organisation when it has not been.
Endorsements or official-looking symbols should make clear the organisation setting the standards, the nature of the standards and the certification process involved. Where a symbol appears on a product because the manufacturer has sponsored the organisation whose symbol it is, this too should be made clear.
The legal framework
This code does not detract from the powers available to the authorities under the law - indeed, it should strengthen the role of those authorities. Within the UK, Trading Standards Officers have powers under the Trade Descriptions Act to deal with claims which are demonstrably false or are found to be misleading. The Director-General of Fair Trading can also take action against misleading claims under the Control of Misleading Advertisement Regulations 1998. The Government is working with the Office of Fair Trading and the local authority trading standards services on the enforcement of the existing measures for tackling unacceptable green claims. It is also considering what further action would help to deter bad practice and support the efforts of businesses which are acting responsibly on green claims.
Claims made in advertisements are subject to the codes administered by the Advertising Standards Authority, the Independent Television Commission or the Radio Authority. These bodies will take appropriate account of the detailed guidance in ISO 14021 when investigating complaints about environmental claims.
Complaints about green claims
If you are puzzled by a green claim about a product, or think it may be misleading, you can take the following action:
- First, you can contact the head office of the manufacturer making
the claim (or the retailer's head office, if the product is the retailer's
'own brand'). Ask for an explanation of the claim. Ask how it can be
shown to comply with the Green Claims Code.
- Where you believe that a green claim is simply untrue, or even
after explanations from manufacturer or the retailer you believe that
a claim may be misleading, it is best to take this up with your
local authority trading standards department. Give them details of the
claim that you believe may be false or misleading, and any other information
that is relevant.
- Complaints about a claim in a radio or TV advertisement can be made to the Radio Authority or the Independent Television Commission. Complaints about printed or cinema advertisements or those on the Internet can be made to the Advertising Standards Authority.
You can contact these organisations at the following addresses:
For trading standards departments, look for 'Trading Standards' in the phone book under your local Council.
14 Great Queen Street
London WC2B 5DG
Tel: 020 7430 2724
Independent Television Commission
33 Foley Street
London W1P 7LB
Tel: 020 7255 3000
The Advertising Standards Authority Ltd
2 Torrington Place
London WC1E 7HW
Tel: 020 7580 5555
Copies of the international standard ISO 14021 can be purchased from:
British Standards Institution
Customer Services Department
389 Chiswick High Road
London W4 4AL
Tel: 020 8996 9001
Fax: 020 8996 7001
Further copies of this code are available from:
London, SW1A 2XX
Email orders: email@example.com
Telephone orders: 08459 556000
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Page last modified: 1 September 2006
Page published: 17 June 1998