Guidelines for the Prevention and Regulation of Greenwashing, 2024

File. No.-CCPA/28/2023-CCPA

Background

Central Consumer Protection Authority has notified guidelines for Prevention and Regulation of Greenwashing, 2024 to ensure control over greenwashing advertising by advertisers and publish of any environmental claims.

In this article, let us understand about the applicability, non-applicability, prohibition of usage of various claims, disclosures required by the advertisers and other matters related to environmental claims by any advertiser.

A. Explanation of terms ‘Greenwashing’ and ‘Environmental Claims’

  1. Meaning of term ‘Greenwashing’
    1. Any deceptive or misleading practice, which includes concealing, omitting, or hiding relevant information, by exaggerating, making vague, false, or unsubstantiated environmental claims.
    2. Use of misleading words, symbols, or imagery, placing emphasis on positive environmental aspects while downplaying or concealing harmful attributes.

but shall not include (i) use of obvious hyperboles, puffery, or (ii) the use of generic colour schemes or pictures; either not amounting to any deceptive or misleading practice.

  1. Meaning of term “Environmental claims’– Any representation, in any form, regarding:
    1. A good (either in its entirety or as a component), the manufacturing process, packaging, the manner of use of the good, or its disposal;
    2. A service (or any portion thereof) or the process involved in providing the service, suggesting environmentally friendly attributes.

B. Applicability (Clause 3 and Clause 4):

These guidelines are applicable to:

  1. All advertisements regardless of form, format or medium;
  2. A service provider, product seller, advertiser, or an advertising agency or endorser whose service is availed for the advertisement of such goods or services.

Note: These guidelines shall not apply to any advertisements or communication that is not specific to any product or service, unless the advertisement or communication directly or indirectly links to any product or service.

C. Prohibition against engaging in Greenwashing (Clause 5): No person to whom these guidelines apply shall engage in greenwashing.

 

Environment claims should always be True and Accurate, and they must be based on verifiable information by means of certificates by statutory authorities, certificates by credible authorities or internal verifiable evidence.

 

Illustrations

Illustration 1: “Our packaging is made from 100% recycled materials.” Without verifiable evidence or certification, this claim might be misleading.

 

Illustration 2: “Energy-efficient technology for a greener tomorrow!” Without providing specific data or comparisons, this claim may lack substance.

D. Substantiation of Environmental Claims (Clause 6): All advertisement making environmental claims shall comply with following obligations:

  1. Generic terms such as’ clean’, ‘green’, ‘eco-friendly’, ‘eco-consciousness’, ‘good for the planet’, ‘minimal impact’, ‘cruelty-free’, ‘carbon – neutral’ and similar assertions shall not be used without adequate qualifiers and substantiation and adequate disclosure as provided under clause (9) of the guideline.
  2. While using technical terms like Environmental Impact Assessment (EIA), Greenhouse Gas Emissions, Ecological Footprint, one shall use consumer friendly language and explain the meaning or implications of technical terms.

The claims should be clear and unambiguous.

Illustrations:

Illustration 1: “Go green with our product!” The claim is unclear and ambiguous, as it doesn’t specify what does the word ‘green’ convey or how the product is environmentally friendly. Hence case adequate qualifiers and substantiation should be provided.

Illustration 2: “Harnessing the power of sustainable technology!” In relation to such a claim, specific details about how the technology is sustainable should be disclosed.

Illustration 3: “Made with minimal impact on the environment!” Without specifying what “minimal impact” means, this claim may downplay or ignore certain environmental concerns associated with the product

  1.  All environmental claims shall be backed by verifiable evidence.
  2. Claims should be absolute and relevant: If a claims pertains to a specific feature, part or stage then the fact that the claim relates only to relevant feature, part or stage should be fully disclose that is relevant for such product.

Illustrations:

Illustration 1: “A packaged product is labelled with an unqualified claim, “recyclable.” It is unclear from the type of product and other context whether the claim refers to the product or its package.”

Illustration 2: “A product in a multi-component package, such as a paperboard box in a shrink-wrapped plastic cover, indicates that it has recycled packaging. The paperboard box is made entirely of recycled material, but the plastic cover is not it may be misleading. The accurate claim could be paperboard box-recycled packaging”.

Illustration 3:- “A marketer advertises on the bottle of its Hand wash as “biodegradable” without qualification. The advertisement shall makes clear that only the Hand wash, and not the bottle, is biodegradable.

  1. Use of imagery without substantive changes: Any form of visual environmental claim attempting to manipulate the consumer into believing that a product or service is environmental responsibility or eco-friendliness, without providing relevant details or context.

Illustration 1: A detergent advertisement showcases a family happily playing in an open grass ground, with the tagline, “Gentle on Clothes, Gentle on Nature.” Without directly stating environmental friendliness, the imagery implies a connection between the product and a more eco-conscious lifestyle

E. Adequate Disclosures (Clause 7):

  1. All environmental claims shall be accurate and disclose all material information either in the relevant advertisement or communication or by inserting a QR Code, URL which will be linked to relevant information.
  2. While making disclosures in relation to environmental claims, data from research shall not be only limited to highlight only favourable observations while obscuring others that are unfavourable.
  3. Any person making an environment related claim should specify whether it refers to the good, manufacturing process, packaging, manner of use of the good or its disposal; or service (or part thereof) or the process of rendering the service.
  4. Comparative environmental claims that compare one product or service to another must be based on verifiable and relevant data that is disclosed to the consumers. Comparative claims must disclose exactly what aspects are being compared.
  5. Specific environmental claims such as Carbon Offsets, carbon neutral, Compostable, Degradable, Free-of, Sustainability claims, Non-Toxic, 100% Natural, Ozone-Safe and Ozone-Friendly, Recyclable, Refillable, Renewable, and similar assertions must be supported by disclosure about credible certification, reliable scientific evidence, or independent third-party verification.
  6. The disclosures made in relation to the environmental claims shall:
    1. Be easily accessible to the consumer.
    2. Not contradict the relevant environmental claim.

F. Futuristic Environmental Claims (Clause 8):

Aspirational or futuristic environmental claims may be made only when clear and actionable plans have been developed detailing how those objectives will be achieved.

G. Guidelines not in derogation of other laws (Clause 9):

  1. Where greenwashing is regulated under any other specific law for the time being in force or the rules or regulations made thereunder, the provisions contained in these guidelines shall be in addition to and not in derogation of, such regulation in other laws, except where provisions of the other specific laws being in conflict with these guidelines, the specific law shall prevail.
  2. Fair and meaningful comparisons: The advertisement or claim should be fair and should have a meaningful comparison.

Illustrations

Illustration 1: “Our energy-efficient light bulbs outperform all others!” The claim lacks context and does not specify which bulbs are being compared. For fair and meaningful comparisons, the company should compare its bulbs to others with similar characteristics and intended uses.

Illustration 2: “Chemical-free cleaning for a safer environment!” This claim may mislead consumers by implying that other cleaning products are unsafe.

Illustration 3: “Our product is greener than the competition!” Without providing specific details about which environmental attributes being compared, this claim can be misleading.

  1. Endorsement by environmental organizations or experts or other endorsers: Claims suggesting endorsements, certifications, or seals of approval that (i) are non-existent, (ii) are intentionally misleading, or (iii) originate from nonofficial bodies and lack recognition from credible authorities then it is misleading; shall not be made.

Illustrations

Illustration 1: “Recommended by leading environmental experts!” This claim implies an endorsement by environmental organizations. This may violate the Guidelines, if there is no backing as specified above.

Illustration 2:- Labelling a product as “certified organic” without proper certification from recognized organic certifying bodies, creating a false advertisement.

Illustration 3:- An electronic product affixing counterfeit energy efficiency labels on appliances to give the impression that they meet certain standards when, in reality, they do not have.

Disclaimer: The information contained in this Article is intended solely for personal non-commercial use of the user who accepts full responsibility of its use. The information in the article is general in nature and should not be considered to be legal, tax, accounting, consulting or any other professional advice. We make no representation or warranty of any kind, express or implied regarding the accuracy, adequacy, reliability or completeness of any information on our page/article. 

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