Consumer Products - Green Claims Code

Responsible businesses, wanting to give environmental information about their products, will find it useful to follow the Green Claims Code issued by DEFRA. 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.
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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 ISO14021 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:

· Compostable
· Designed for disassembly
· Extended life product
· Recovered energy
· Recyclable
· Recycled content
· Reduced energy consumption
· Reduced resource use
· Reduced water consumption
· Reusable and refillable
· Waste reduction
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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 in question.

· 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 and specific.

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.

Further information on making green claims can be found on the DEFRA website at www.defra.gov.uk
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