A Quick Guide to the ACCC Guidelines on Environmental Claims

A Quick Guide to the ACCC Guidelines on Environmental Claims

In case you missed it, the Australian Competition and Consumer Commission (ACCC) recently released its draft guidelines for businesses on environmental and sustainability claims.

This publication acknowledges that consumers are increasingly considering such claims to make purchasing decisions. If a business made false or misleading claims (commonly known as “greenwashing”), it would give them an unfair advantage over more truthful competitors and risk diminishing the trust of its customers. 

To help businesses remain truthful, trustworthy and out of trouble with the ACCC, the guidelines are broken down into eight principles.

While the guidelines aren’t yet enforceable, their release indicates that environmental regulation is ramping up and savvy businesses should get on top of things now.

To help with this process, WolfPeak have got our hands dirty and dived into the details of the guidelines. From this, we’ve extracted some key principles to get you started and give your business actionable steps to go above and beyond environmental compliance. 

If you need more guidance or some tailored steps to act, get in touch with our expert team. They’ll help you to boost both the environment and your bottom line today — it’s just the WolfPeak way!

Principle 1: Make Accurate and Truthful Claims

The only way to ensure you’ve been accurate and truthful is by responsibly measuring and reporting your activities. 

WolfPeak offers services from risk, audit and compliance to environment and sustainability management and strategy This includes carbon accounting and accounting for nature. These allow you to make environmental statements and be totally sure of the research behind them. Big businesses can’t risk non-compliance, so it pays to know that your Sustainability webpage is water tight. 

To ensure the accuracy of your claims, the guidelines outline five do’s and don’ts:

  • Do not overstate the level of scientific acceptance
  • Do not exaggerate the environmental benefit
  • Only make meaningful claims
  • Make sure comparisons are transparent and fair
  • Clarify that representations about the future are goals only and not certain.

At WolfPeak, our rule of thumb is that truth and transparency always trump outlandish greenwashing. There is no point in exaggerating your efforts because consumers are generally satisfied by a brand that is genuine and doing the best it can.

Principle 2: Have evidence to back up your claims

That being said, a bare minimum is certainly becoming clear, and this comes with the expectation that your claims are well-researched. 

If you aim to achieve a certain level of emissions reduction by 2025, you’ll need clear, measurable, and achievable steps to do so. 

Similarly, if you have already achieved a sustainability goal, such as replacing a portion of your power consumption with solar energy, such measures will need robust calculations to back them up. 

These can be obtained through a trusted third party (that’s us!), a scientific study, or a widely-accepted methodology — or better yet, all of the above. 

As with each of these principles, the point of such evidence is to improve trust with your customers.

If you’re aiming for best practice, this supporting evidence should be made publicly available to consumers, as such claims are generally difficult to verify. 

Our final point on this principle is to verify and understand the research yourself before making it public. While most businesses and research teams can be trusted, you’ll rest easier knowing that their work has helped and not hindered your business. Plus, when a customer asks you to explain how you’re benefiting the environment, you can rattle off all those beautiful facts and figures. 

Principle 3: Don’t Leave Out or Hide Important Information

There’s no worse way to lose consumer trust than making inaccurate claims, but omitting key information to mislead consumers comes pretty close. 

If your business is truly sustainable, it won’t feel the need to lie. And if you’re not very sustainable yet, consumers do understand! Your best bet is to be truthful and commit to improving your business. 

The guidelines provide an example of an airline that claims to be “reducing emissions.”

In actual fact, the hypothetical airline is referring to the biofuel used on a minority of its flights, while flights with carbon-intensive jet fuel continue to increase. 

If the ACCC investigated, it would make one of two conclusions: the airline knowingly misled consumers with greenwashed buzz phrases like “reducing emissions,” or, it wasn’t aware that omitting facts to appear more sustainable can be equally as damaging. 

In any case, the airline would receive a fine for breaking Australian Consumer Law. The moral of the story: tell the whole truth and nothing but the truth!

Principle 8: Be Open About Your Sustainability Transition

Jumping ahead to continue the previous point, it’s always best to be open and honest while you improve your business. Consumers understand that very few brands are perfect, but they appreciate those who are doing their best.

Using our Strategic Advisory services, you can outline clear goals that will help you to achieve more sustainable (and profitable) operations!

The guidelines have provided more helpful do’s and don’ts when publicising your place in the sustainability transition:


  • Be sure of your motivation for making environmental claims. Is it because you’ve made genuine progress to benefit the environment, or are there more selfish reasons behind it? 
  • Be realistic about the changes you can achieve throughout the transition. Do they rely on technological advancement or policy change, or will you have the total capacity to achieve your goals? 
  • Be sure that the sustainability terminology you use is correct and that it will be widely understood by your audience. 
  • Be clear about the steps you’ll take to achieve each goal. 
  • Be clear about which steps have been completed and when future ones will be completed.
  • Provide regular updates on your progress, highlighting any successes as well as any hiccups in the process. 


  • Claim that you plan to act if this is not the case.
  • Claim that you’ve undertaken certain activities or improved your performance if you have not yet done so.
  • Claim to have achieved steps in the transition if they’re still in progress. 

Consult with WolfPeak

To keep things simple, we won’t rattle through all eight principles, but they’re freely available on the ACCC website.

If you need support putting these guidelines into action, contact our team for a 30-minute conversation.

With a better understanding of the implications, you too can benefit the environment and the economy, not to mention your bottom line.

Image Source:

Capability Statement