The International Chamber of Commerce (ICC) has published an updated framework for responsible environmental marketing, which aims to prevent the use of misleading claims to promote “green” products and services.

Known as the ICC Framework for Responsible Environmental Marketing Communications – or Environmental Framework for short – the document provides further guidance in response to the growing complexity of environmental and green marketing claims.

These include general claims of “sustainability”; new, emerging climate-related claims; recyclable content and degradability claims; and additional “free-of” claims.

The revised Environmental Framework will supplement the ICC Advertising and Marketing Communications Code – which was first adopted in 1937, and was most recently updated in 2018.

According to an ICC statement, the framework offers guidelines for advertising industry stakeholders to use in developing and analysing environmental claims, consistent with the general principles of the ICC Advertising and Marketing Communications Code.

As such, the framework aims to assist marketers in assuring that self-declared environmental claims are truthful, not misleading to consumers, and are appropriately substantiated.

Going green – The evolution of the ICC Code and Chapter D

Since its original publication in 1937, the ICC Code has set forth general principles governing marketing communications of all types and in all media. 

It also includes a separate section, Chapter D, on environmental marketing communications.

For many years, the General Code and Chapter D have been augmented by the ICC Framework for Responsible Environmental Marketing Communications (or Environmental Framework).

The ICC said the updated framework continues to reflect its longstanding principle that all claims are evaluated in the context in which they appear, and that marketers should consider the net impression of the claim as a whole. 

The ICC Code and the Environmental Framework thus offer a roadmap for global marketers in developing environmental claims and campaigns.

Significant changes to combat greenwashing

The updated 2021 Environmental Framework provides added guidance on some established environmental claims, and additional guidance on some emerging claims, such as:

  • Climate-related claims: including carbon footprint, carbon offset, carbon neutral, carbon
  • negative, net zero, and climate positive. These may be aspirational claims related to goals of
  • reducing, neutralising or compensating a company’s climate impact of producing a product,
  • component, package, service or a company’s business operations over time.
  • Circularity claims: including circular, circularity, and circular economy
  • Additional “free-of” claims: including “micro-plastics free” and “not made with fossil fuels”
  • Recyclability claims and the use of material identification codes
  • Recycled content claims
  • Degradable claims: including biodegradable, marine degradable, oxo-biodegradable, and
  • Photodegradable

The ICC notes, however, that not all terms are subject to globally agreed definitions or criteria, so the framework does not attempt to offer specific definitions in all instances. 

Rather, the framework reminds marketers to take steps to assure that all environmental claims are clear and appropriately substantiated by sound scientific evidence. 

As with all guidance issued by the ICC Marketing and Advertising Commission, the ICC said its Environmental Framework is grounded in the principle that freedom of commercial speech in the sale of legal products and services is a fundamental tenet of free markets. 

The ICC believes that free markets promote innovation, economic development, and competition, as companies compete to provide consumers with products and services that reflect their interests and concerns and offer them a range of choices. 

In its introduction to the new framework, the ICC adds that global business leaders are “keenly aware that the proper functioning of a free-market economy depends on consumers receiving accurate and truthful information about products, services or operations.”