Environmental Claims

Consumer need to have accurate, truthful, and evidence-based information when it comes to seeing and understanding environmental claims. Greenwashing is the practice of making false or misleading environmental claims about a product, packaging, policy, activity, etc. 

There continues to be increased global activity and enforcement around environmental claims and greenwashing. Canadian companies do not have currently have guidelines or updated resources for making environmental claims.  In November 2021, the Competition Bureau archived Environmental claims: A guide for industry and advertisers – which was prepared in 2008 by the Bureau and the Canadian Standards Association to guide industry and advertisers on environmental claims – stating that the document “may not reflect the Bureau’s current policies or practices and does not reflect the latest standards and evolving environmental concerns.” The guide continues to be available online for reference, but the Bureau stated that it would “not be altered or updated as of the date of archiving.”

In general, environmental claims must be clear, accurate, and based on fact and data. Recyclable claims are based on whether the consumer can send the material for recycling, not whether it is technically capable of being recycled. In Canada, the definition of “recyclable” for environmental labelling purposes has been understood to mean that a reasonable proportion of the population has access to recycling, which is 50% in Canada. According to a study commissioned by PPEC, 96% of Canadians have access to recycling for corrugated boxes and paper bags, and 94% for boxboard cartons, which means that Canadian box, bag, and carton manufacturers can print the word “Recyclable” and use the Recyclable logos on their packaging.

Making Environmental Claims in Canada

Any company which puts forward environmental claims on their products or packaging are reminded that they need to know the applicable laws to ensure they are making informed legal decisions and evidence-based claims.

PPEC has historically pointed its members in the direction of the Competition Bureau’s now archived Environmental Claims guide, in addition to providing information and data about access to recycling, which has typically been used to determine if paper packaging can be labelled “recyclable.” While this might change in the future, in Canada the definition of the word “recyclable” for environmental labelling purposes has been understood to mean that a reasonable proportion of the population – which is 50% in Canada according to the Competition Bureau (and 60% in the U.S. according to the FTC) – has access to the recycling of that packaging.

In general, PPEC advises against using vague terms, broad statements, or “100%” claims. Environmental claims must be clear, accurate, evidence based, and comply with existing Canadian legislative obligations such as the Competition Act, Consumer Packaging and Labelling Act, and the Textile Labelling Act.