The International Chamber of Commerce (ICC), the world's largest business organization, has updated its guide "Framework for Responsible Environmental Marketing Communications".

Based on this updated guide, we summarize important environmental claims. Interestingly, marketers should take appropriate steps to assure that all environmental claims are clear, truthful, qualified as needed, and substantiated by reliable scientific evidence.

Climate-related claim

• Vague, general claims include claims such as “environmentally friendly," “good for the environment,” “ecologically safe,” “green,” “sustainable,” “carbon-friendly,” “climate-smart” or any other claims implying that a product or an activity has no impact — or only a positive impact — on the environment. General environmental claims should not be used without qualification unless proof is available, or the claim is linked to a specific properly substantiated environmental attribute.
• Claims should not state or imply that an improvement in performance is more significant than it is. For example, a claim that a component was produced with “30% lower carbon emissions” when the carbon emissions of the component are a small fraction of the emissions of the product as a whole would be misleading without qualification to contextualise the relatively low impact of the reduction in that specific component.
• The marketers making carbon or climate claims, including advertising commitments that they expect to achieve or will be realised in the future, should be clear and include qualifiers as needed regarding the method, basis, and time frame relied upon for such commitments to be realised. Claims should use the same time scales for emissions, emissions reductions, and offsets.
• The marketer should make sure that the marketing communications activities observe applicable laws and regulations in the market in which the claim is directed.

Circularity claim

• The concept of “circularity” or a “circular economy” is based on reducing waste through actions such as sharing, leasing, reuse, repair, refurbishment, and recycling to improve management of resources, reduce waste, and reduce climate impacts.
• At present, there is no agreement on standards to apply in connection with claims that products or processes are “circular”. Any claims of circularity should be based on an appropriate assessment and marketers should make clear what is meant by the claim and disclose the basis for the claim.

Free-of claim

• A "free-of" claim for a product that contains some amount of a substance could be made if there is a trace amount of the substance that was not intentionally added.
• It is deceptive to make a “free-of” claim if a product:
  • contains another substance that may be harmful to human or animal health or the environment, or
  • contains a substance that was never associated with that product or product category, or
  • contains a substitute that has the same or a similar impact, even if at a lower level.

Recyclable claim

• To support a recyclable claim, the marketer should have reliable evidence that the product/packaging can be diverted from the solid waste stream and actually made into another useful product. Also, the ability of the product to be recycled at an industrial scale should be considered.
  • Definition according to the NF EN ISO 14021 standard "A characteristic of goods, packaging or associated component that can be diverted from the waste stream through available processes and programs and can be collected, processed and returned to use in the form of raw materials or goods"
  • NF EN 1343024 standard requirements: “Make sure that the materials or combination of materials used in the design of packaging are compatible with industrially known, available, and relevant recycling techniques […]"
• Marketers should specify whether an environmental claim applies to a product, to part of the product, or to its packaging.
• The claim should be qualified enough to specify whether the product/package is merely capable of being recycled or can actually be recycled in the local community.
• An unqualified claim of “recyclability” includes the terms “recyclable,” “100% recyclable,” and “please recycle.” “Recyclable where facilities exist” is also viewed as an unqualified claim of recyclability under most guidance and requires further disclosures regarding the availability of collection facilities where they are limited.
• The "recyclable" claim should be qualified in cases where around 60% of consumers/communities have no access to the recycling facilities. Therefore, the claims “Not widely recycled—check locally” or “Recycling facilities are limited—check locally” should be mentioned accordingly.
• Claims that a product or package is recyclable through a take-back programme (where the manufacturer accepts the material back for recycling into the same or another product) should clearly specify the product, packaging, or component that is recyclable, the steps the consumer needs to take to return it to the producer or manufacturer, and limitations on availability. For example, batteries that are recyclable through participating national retailers could claim “Recyclable. Drop off at participating national retailers, including [list major partners].”
• A product that is refillable or reusable, or that contains or is made with recycled content, is not necessarily recyclable.

Recycled content claim

• This claim refers to recycled material that has been either diverted from the waste stream during a manufacturing process or generated by end-users.
• It should be specified whether the product, packaging, or component has recycled content.
• If a product or package is made partly of recycled material, a percentage qualifier by weight is needed (e.g., "Made from 60% recycled material").
• Claims that a product contains “up to” a specified percentage of recycled content may be deceptive depending on the amount involved; claims specifying the minimum amount of recycled content the product or package contains are often preferred.
• The claim "Made from recycled content” may be deceptive if the environmental costs of using recycled content outweigh the environmental benefits of using it.

Mobius Loop

• Mobius Loop consists of three twisted chasing arrows forming a triangle. The arrows are flipped over and are relatively thick.
• The Mobius Loop should not be confused with material identification code markings, including the Resin Identification Code (RIC) marking that identifies a specific type of plastic. This is also a triangle with arrows.
• The Mobius Loop conveys recyclable, and/or recycled content, and thus the symbol should be accompanied by an informative statement, e.g., the words “recyclable” (with appropriate qualifiers) or “x% recycled content”.
• It should be specified whether the symbol relates to the product and/or packaging.

Degradable claim (including biodegradable, marine-degradable, oxo-biodegradable, and photodegradable)

• It should not be made for a product/packaging, which releases substances in concentrations harmful to the environment.
• An unqualified claim could be made if there is reliable evidence that the product/packaging will degrade in all potential disposal environments.
• Otherwise, a qualified claim is needed describing the maximum degradation level, the test duration, and the specific environment in which degradation occurs.
• Further, tests should be conducted on the actual product (or one that is substantially identical) to assure the results are applicable to the product for which the claim is made. For example, tests on raw materials (e.g., the biodegradability of the concerned material) may not be fully representative of the performance of finished products (e.g., the biodegradability of a container made of that material); if they are not, the tests may not provide adequate substantiation for the claim.
• It should be specified whether the biodegradable claim refers to the product, packaging, or component.
• “Please dispose of responsibly” or “Do not litter" are recommended at the same time to prevent littering.
• In some regions, specific test methods are required to use the "degradability" claim.

Compostable claim

• Reliable evidence is needed showing that all the materials in the product/package will break down into or become part of usable compost.
• The claim should not be made for a product/packaging, which releases substances that negatively affect the ability to form usable compost.
• It should be clearly disclosed if there are limitations on the availability of specific facilities.
• If the product is compostable only in certain environments, qualifiers should be included.
• The timeframe in which materials are expected to compost should be considered and always consistent with other materials composted under the same conditions.
• It should be specified whether the compostable claim refers to the product, packaging, or component.

Reusable/Refillable claim

• Reusable: A characteristic of a product or packaging designed to accomplish within its life cycle more than one application, or use for the same purpose for which it was designed.
• Refillable: A characteristic of a product or packaging that can be filled with the same or a similar product more than once, in its original form, and without additional processing except for specified requirements such as cleaning or washing. The marketer should generally also provide a means for the product to be refilled.
• No product or packaging should be described as reusable or refillable unless it can be reused or refilled for the same or similar purpose. Such claims should be made only where products exist for the same purpose. If there is a limit, based on safety, quality, or other reasons, on the number of times the product or package may be reused or refilled, those limits should be disclosed.
• A product that is refillable or reusable, or that contains or is made with recycled content, is not necessarily recyclable.

Made with Renewable Materials

• A material is renewable if the resource is managed to assure that it will not be depleted. Reference to the timeframe in which the product may be renewable may be appropriate if consumers may not understand the timeframe at which the resource is replenished.
• An unqualified claim of renewability should not be made unless the product or package consists of 100% renewable content, excluding minor, incidental components.
• The percentage of renewable materials should be specified.
• Claims that a product contains “up to” a specified percentage of renewable material may be deceptive, especially if the range of renewable material used is broad.