ICC issues new guidance on environmental claims in marketing and advertising

As consumers become more interested in the environmental footprint of the products they buy, the updated ICC Framework for Responsible Environmental Marketing Communications (the “ICC Framework”) helps marketers evaluate environmental communications to maintain consumer confidence in these claims. The ICC Framework helps marketers craft environmental messages that adhere to the basic global principles of truthful, honest and socially responsible communications.

The climate crisis has sparked growing momentum on climate action globally, including collective efforts by governments and businesses to mitigate the threats of climate change. COP26 brought to the fore a surge in commitments to reach net-zero emissions by 2050, in line with the goals of the Paris Agreement.

Increased interest by the media, government, consumers, and other stakeholders about the impact of human activities on the environment and how to promote sustainable consumption and a circular economy has put the spotlight on environmental marketing claims.  The marketplace has seen a proliferation of environmental claims as businesses seek to promote the environmental attributes of their products as well as communicate their climate ambitions with the broader public.  Helping businesses get these messages right is a core objective of the updated ICC Framework.

“While the principles behind good environmental marketing are simple, applying them to new claims and terms that are not universally understood, and making sense of available data and science, adds a level of immense complexity,” said Sheila Millar, Partner Keller and Heckman, and Vice-Chair of the ICC Commission on Marketing and Advertising. “The ICC Framework helps companies map that process and provide guidance for self-regulators to consult when claims are questioned.”

The updated ICC Framework addresses some emerging claims seen in the marketplace, including terms such as “net-zero’, “climate positive”, “carbon neutral”, “micro-plastics free”, “not made with fossil fuels”, and updated guidance on claims like “compostable”, “biodegradable” and others.  It also discusses standards for the growing number of aspirational claims, which are increasingly common as more and more businesses around the world make commitments to reduce climate impacts. Companies communicating aspirational claims to reflect the environmental commitments or climate goals they aim to achieve in future years — such as “net-zero by 2050” – should be able to concretely demonstrate the methodological approach they are using to enable them to meet those commitments.

The ICC Framework also provides guidance related to recyclability claims and the use of material identification codes such as the Mobius loop.

“Even a widely recognised symbol like the Mobius loop – the so-called “chasing arrow” symbol – does not necessarily communicate something universally understood by consumers. When a consumer sees this symbol, what do they infer about the product? That it has been recycled? Is recyclable? Or both? Placement and conspicuousness also matter,” Ms Millar said. “The ICC Framework is designed to help walk advertisers through a review process that maintains a focus on how a consumer might interpret a particular advert or claim.”

Features of the ICC Framework for businesses include access to a detailed checklist aimed at the creators of marketing communications around environmental claims, and a chart providing easy reference to relevant provisions of the global Advertising Code, and interpretations on current issues related to environmental marketing.

As many of the national and regional codes are built on ICC’s Codes, this interpretation can also be applied to national and regional marketing codes used by self-regulatory organisations to set best practices for business.

Helping to make sound environmental messaging everyone’s business, the ICC Framework encourages business to come together and adopt common standards for environmental marketing communications to ensure responsibility and build consumer confidence.

Download the ICC Framework for Responsible Environmental Marketing Communications