Marketing & advertising

ICC response to European Commission’s Green Claims Directive

  • 27 July 2023

Read the ICC comments in response to European Commission's Directive

ICC supports the aims of the proposed European Commission’s Green Claims Directive but considers the proposed approach to be misguided. Our feedback has been prepared through an open consultative process with members from our global network with comments accessible in this document.

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Ensuring responsible marketing practices worldwide has been a long-standing ICC commitment. We will continue to work with self-regulatory agencies and businesses to enforce advertising standards through adherence to both the ICC Advertising and Marketing Communications Code and the specific rules and guidelines set out in the ICC Framework for Responsible Environmental Marketing Communications

ICC reiterates the importance of a harmonised view on how to substantiate environmental claims and has long standing expertise in helping marketers craft environmental messages that adhere to the basic global principles of truthful, honest and socially responsible communications. To that end, ICC agrees with the overarching aims of the EC’s Directive, i.e., the importance of accelerating the green transition and the need to ensure that environmental claims are well-substantiated to avoid greenwashing and empower consumers to make environmentally sound choices.

It is concerning that the EC’s Directive proposal does not at all consider existing self-regulatory measures by industry, such as the ICC Advertising and Marketing Communications Code, and the specific rules and guidelines set out in the ICC Framework for Responsible Environmental Marketing Communications. Moreover, ICC’s re-branded Environmental Claims Checklist of the Environmental Framework is an additional resource to help marketers identify when they are making an environmental claim, offering guidance on questions about such claims in an easy-to-follow format. Not only are the ICC Marketing Code provisions and interpretations applied by self-regulatory organisations, they are also recognised by and have inspired national marketing legislation and self-regulatory initiatives across the globe. Aligning the proposal with the rules of the ICC Code not only secures a high ethical standard, but also counteracts regulatory fragmentation at an international level.  

ICC believes that the proposed Directive is likely to add costs and complexity, rather than taking into account the important role served by self-regulation. The additional time and expense are likely to result in companies avoiding environmental messaging, which could further lead companies to reduce their environmental efforts, as the costs of marketing environmental initiatives may outweigh the potential benefits. 

As a leader in responsible marketing worldwide, ICC intends for its ICC Marketing Code and the Environmental Framework to serve as key practical resources for practitioners developing environmental claims and campaigns. In this sense, ICC advocates for a constructive dialogue between our organisations to ensure the practicality and effectiveness of the Directive, drawing upon ICC’s extensive experience in promoting sound marketing and advertising practices. 

Also read
ICC welcomes European Commission’s Green Claims Directive

ICC position paper on the Green Claims Directive – 30 May 2024

ICC reiterates its concerns regarding the proposed ex-ante verification mechanism outlined in the Green Claims Directive. Feedback from our member companies, who actively pursue high climate ambitions, highlights apprehensions due to anticipated administrative burdens, increased costs, broad scope, and potential conflicts with constitutional provisions that explicitly forbid censorship.