If your evidence says a bottle body contains 80% recycled stainless steel, your claim should not say "80% recycled bottle" unless the remaining components are included in the calculation.
That small change - from bottle body to bottle - can turn a specific, supportable statement into a misleading impression.
This is the problem the Australian Competition and Consumer Commission focuses on. Environmental claims are assessed by the overall impression they create, not by the technical defence hidden in a supplier email.
The safest process is not to ban every useful claim. It is to make the claim specific, link it to evidence, disclose important conditions and keep the record current.
The ACCC has retained consumer and fair-trading issues relating to environmental claims as a 2026-27 compliance and enforcement priority. Product suppliers, distributors and retailers should treat claim governance as an operating process, not a marketing tidy-up.
The ACCC's eight principles
The ACCC's business guidance sets out eight principles for trustworthy environmental claims:
- Make accurate and truthful claims.
- Have evidence to back up claims.
- Do not hide or omit important information.
- Explain conditions and qualifications.
- Avoid broad and unqualified claims.
- Use clear and easy-to-understand language.
- Ensure visual elements do not give the wrong impression.
- Be direct and open about sustainability transition.
These principles are practical. They can be turned into a product-claim workflow.
Start with the impression, not the sentence
A technically accurate phrase can still mislead through context.
Consider:
- Product name
- Headline
- Icons
- Colours
- Nature imagery
- Placement
- Footnotes
- What is omitted
- What an ordinary buyer is likely to infer
A green leaf beside "responsible range" may imply independent endorsement even if no certification is named. A small qualification at the bottom of a page may not correct a sweeping headline.
Review the complete product page, pack, catalogue entry or tender response. Do not approve environmental wording in isolation.
Build a claim record
For every material environmental claim, create a controlled record containing:
- Exact approved wording
- Product and SKU
- Component or scope
- Market and channel
- Evidence
- Evidence owner
- Calculation method, if relevant
- Conditions and qualifications
- Approval date
- Review date
- Expiry date
- Published locations
This record makes the business able to answer a simple but uncomfortable question: "Why did we say that?"
If the answer is "the supplier's brochure used the same words", the claim is not ready.
A seven-step substantiation process
1. Define the claim precisely
Write what the business wants the customer to understand.
Bad starting point: "Sustainable cup." Better starting point: "The cup's paperboard is made with 100% recycled fibre."
That is still not publishable until the evidence, component scope and any food-contact or material qualifications are checked. But it can be tested. Broad terms such as "green", "eco-friendly", "environmentally safe" and "sustainable" can imply benefits across the full lifecycle. The broader the claim, the broader the evidence burden.
2. Define the product, unit and boundary
Specify which SKU or family, which component, the percentage basis, geographic market, lifecycle stages and time period.
For a carbon claim, state whether the result is per individual unit, pack or carton and whether it covers cradle-to-gate or the full lifecycle. For recycled content, state whether the percentage is by mass and whether it applies to the whole product or a named component. For recyclability, state relevant conditions and collection context.
3. Collect appropriate evidence
Evidence quality depends on the claim. Possible sources include:
- Test reports
- Current certificates
- Chain-of-custody records
- Bills of materials
- Supplier declarations
- Transaction certificates
- Lifecycle studies
- Product carbon footprint reports
- Technical standards
- Waste or recovery data
Check issuer, date, scope, product link, facility, method, limitations and independence. A certificate for a supplier does not necessarily cover the product. A product certificate from last year may not cover the current factory. A recycled-content declaration may exclude accessories.
4. Test the evidence against the likely impression
Ask:
- Does the evidence prove the exact words?
- Does it cover the whole product impression?
- Is a reasonable customer likely to infer more?
- Are material limitations visible?
- Is the comparison like-for-like?
This step catches claim inflation. Data: "30% less virgin plastic by weight than the company's previous 750 ml bottle design." Inflated claim: "30% better for the planet." The second claim expands one material metric into an undefined overall environmental benefit.
5. Add qualifications where they matter
Qualifications should be clear and close to the claim. Examples:
- "Bottle body only; excludes lid and seal."
- "Commercially compostable to AS 4736 where accepted by an industrial composting facility."
- "Cradle-to-gate product footprint; excludes customer delivery, use and end of life."
- "Compared with our 2024 product specification on the same unit and boundary."
A qualification cannot rescue a headline that creates the opposite impression. If the limitation is central, put it in the main wording.
6. Approve the complete communication
Review text, visuals, icons, certification logos, placement, links, footnotes, product filters and comparison labels. Assign approval to a named function - such as sustainability, compliance or legal - according to risk.
High-risk claims may include:
- Carbon neutral
- Net zero
- Plastic free
- Biodegradable
- Compostable
- Zero waste
- 100% recycled
- Broad comparative claims
These deserve more scrutiny than a factual statement of product weight.
7. Monitor and review
Claims can become stale when:
- The supplier changes
- The factory changes
- The material specification changes
- A certificate expires
- A standard is updated
- Recovery infrastructure changes
- The calculation method changes
- New evidence contradicts the old basis
Set a review date and link product-change processes to claim reapproval. Keep a list of every channel where the claim appears so it can be corrected consistently.
How to substantiate common product claims
Recycled content
A strong recycled-content claim states percentage, material, component or whole product, pre-consumer or post-consumer source where relevant, basis of calculation and evidence.
Example: "The notebook cover contains 70% post-consumer recycled polypropylene by weight, based on supplier documentation dated June 2026."
Check whether chain-of-custody certification or transaction evidence is needed for the intended claim. Do not use a facility's general capability to prove the content of every product it makes.
Recyclable
"Recyclable" can create an impression that the item can realistically be collected and processed. Consider:
- Materials and components
- Separation required
- Labels, coatings and adhesives
- Product size and format
- Contamination
- Collection availability
- Sorting and processing
- Geographic market
In Australia, the Australasian Recycling Label can support evidence-based disposal instructions for consumer packaging. Do not improvise a universal recycling logo because the base polymer has theoretical recycling potential.
Compostable
Specify home or commercial composting, applicable standard and certification, whether the whole finished product is covered, required facility or conditions, and availability limitations.
AS 4736 and AS 5810 relate to different Australian composting contexts. A material certificate does not necessarily cover inks, adhesive, lining and the finished item. "Compostable" without a realistic collection pathway may still be technically supportable if conditions are clear, but it can create little practical environmental benefit. Avoid implying guaranteed composting.
Biodegradable
Everything biodegradable does not disappear harmlessly under ordinary conditions. The claim should address environment, conditions, timeframe, test method and residues. Unqualified "biodegradable" claims are risky because customers may infer rapid breakdown in landfill, soil or the ocean.
Carbon footprint
A product carbon claim should state result, unit, boundary, method, calculation date, key limitations and verification status.
Example: "Estimated cradle-to-gate footprint: 1.8 kg CO2e per carton of 100, calculated using the stated product data and methodology in July 2026. Not independently verified."
Do not compare two footprints unless units, functions, boundaries, methods and data quality are compatible.
Lower-carbon
Name the comparison: compared with what product, at what date, on what unit, using what boundary and method, and whether the reduction is absolute or percentage. "Lower carbon" without a benchmark is unfinished.
Carbon neutral
Define product or organisation scope, emissions boundary, reduction activity, residual emissions, offset type, quantity, vintage and retirement, certification or program if any, and claim period. Carbon neutrality does not mean zero emissions. Avoid imagery or wording that creates that impression.
Sustainable or eco-friendly
These claims are usually too broad. Replace them with the specific attribute the evidence supports:
- Contains 80% recycled aluminium
- FSC Mix certified paper, with the applicable claim
- Cradle-to-gate footprint reduced by 18% against the named previous model
- Designed for 500 reuse cycles under the stated test
Specific claims may sound less grand. They give buyers something they can evaluate.
Comparative claims need a fixed baseline
A defensible comparison identifies baseline product, baseline period, functional equivalence, unit, boundary, data method, material differences and result.
Avoid changing both the product and the measurement method and then attributing the entire difference to product improvement. If the new calculator uses different emission factors, recalculate the baseline where possible. If not, explain the limitation.
Certification logos need scope controls
Logos can imply more than text. Before publishing, check:
- Is the company licensed to use the logo?
- Is the certificate current?
- Does it cover the product, site and transaction?
- Are colour, size and placement rules followed?
- Does adjacent wording expand the claim?
A supplier certificate downloaded from a public directory is not automatically a marketing licence for a distributor.
Supplier claims should not be copied blindly
Contracts can require suppliers to provide accurate information and notify changes. That helps. It does not remove the seller's responsibility for the claims it republishes.
Use a supplier evidence standard:
- Required product identifier
- Named component
- Percentage basis
- Test or certificate
- Current date
- Authorised signatory
- Change-notification obligation
Escalate vague claims. "Made from ocean-bound plastic" needs a definition, collection geography, chain of custody, percentage and evidence. The ACCC has taken court action over alleged "50% Ocean Plastic" claims for certain bags. The case is a useful reminder that evocative sourcing language needs a precise, supportable chain of facts.
What happens if a claim is challenged?
The ACCC can investigate and use information-gathering powers. Businesses may also receive substantiation notices in relevant circumstances. Competitors, customers and consumer groups can challenge claims.
Be ready to produce:
- The approved wording
- Evidence held when the claim was made
- Internal approval
- Calculation files
- Qualifications
- Publication dates
- Corrective action
Some contraventions involving false or misleading representations can attract very substantial maximum corporate penalties under the Australian Consumer Law. The exact legal provision matters, so obtain legal advice rather than attaching a generic penalty figure to every claim. The operational lesson is simpler: evidence should exist before publication, not be reconstructed after a complaint.
A practical risk tier
Lower risk
Specific, measurable attributes with current evidence and narrow wording.
Medium risk
Comparisons, certifications, recycling or composting claims that depend on scope and conditions.
Higher risk
Broad environmental benefits, carbon neutrality, future targets, "zero" claims and claims likely to influence a major purchasing decision.
Apply more senior review and stronger evidence as risk rises.
What software should do
Product sustainability software should help a company:
- Store the product unit and scope
- Link evidence to the correct SKU, component, supplier or factory
- Record approved wording
- Flag expiry
- Preserve versions
- Control user permissions
- Show qualifications near outputs
- Track publication channels
- Trigger review when product data change
It should not generate an "eco-friendly" claim automatically from a recycled-content field.
Where Zilch fits
Zilch helps suppliers and distributors maintain product-level carbon and sustainability records across catalogues. That creates the structured evidence layer behind specific claims: materials, weights, footprints, certifications, sourcing data and version history.
It does not provide legal advice or make every claim safe automatically. It helps the business know what it knows, link claims to evidence and avoid treating a supplier's adjective as product data.
If your catalogue contains environmental claims that cannot be traced back to a current product record, see how Zilch works for distributors or book a call with the team.