Guidelines for Environmental Claims - Part 1

Preamble
Scope
Application
Guiding Principles

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Table of Contents

• General Claims / Representations
• Absolute Claims / Representations
• Source Reduction of Materials
• Reusable/Refillable Containers or Products
• Recyclable Materials
• Recycled Content in Materials
• Degradable Materials
• Compostable Materials

Appendices

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General Claims / Representations

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Recognized Standards - Claims should be based on recognized standards or prevailing scientific principles. In the absence of adequate evidence demonstrating that the subject of the claim or representation reduces or minimizes environmental impact, unqualified terms or representations that imply environmental benefit should not be used.

Vague Statements such as "environmentally friendly," "ozone friendly," or "green" are meaningless statements that imply that the identified products or services provide some environmental benefit. In reality, these products do not benefit the environment. The message being conveyed speaks of reduced environmental impact as a result of specific product characteristics. Vague statements or catch phrases cannot clearly indicate specific benefits and should therefore not be used.

Known Substances - Some substances are currently known to have significant adverse environmental impacts. The more common substances that have been identified in consumer products are CFC's, VOC's, heavy metals and excessive levels of phosphates. In an attempt to address consumer concerns, companies remove or reduce the quantity of these substances. However, the replacement substances may not be benign, and may also be damaging in some way, or the reduction may not provide a significant benefit. Any claims relating to the removal of substances that are known to be harmful should therefore take into account the net effect of the change that has been made.

EXAMPLES:

1. if an ozone- depleting blowing agent for expanded foam is replaced with an inert substance, an unqualified claim of reduced environmental impact may be acceptable; however, for the sake of clarity, the claim should be qualified.

2. if one ozone-depleting propellant in an aerosol is replaced with another, the benefit of removing one substance may be offset by the replacement substance and any claim of reduced environmental impact is not appropriate.

If current scientific opinion indicates that the replacement substance is reasonably benign or significantly less harmful, then any claim of reduced environmental impact should indicate that the offending substance has been replaced by a less harmful substance. The replacement substance should be named unless doing so would cause additional confusion. If the replacement substance is known to contribute to environmental degradation, even though the impact may be in a different area than the substance it is replacing, then claims relating to the revised product should not make reference to broad environmental benefit or reduced impact.

Brand Name or Trade-mark - On occasion, a company may use a brand name or trade-mark that appears to relate to the environment. In these cases, where it is determined that the name or mark seems to designate environmentally sensitive products, or gives the impression that the product is environmentally sensitive, the name or mark will be considered an environmental claim. As such, the use of the name or mark will be subject to the appropriate legislation and is expected to be in accordance with the principles contained in this Guide, and, in particular, is to be accompanied by appropriate clarification or substantiation.

Life Cycle Analysis - When making reference to reduced environmental impacts, it would be useful to be able to make comparisons among materials or product classes based on life cycle analysis, or LCA. Some common examples could compare paper and plastic carry out bags or disposable and reusable products. LCAs are generally based on the quantity and nature of resources used and substances released. While these quantities can be determined in most cases, for comparisons among different materials and/or processes, there may be no correlation between resources used, substances released into the environment and the relative environmental impacts of one product over another.

Many organizations, including national, international and private standards writing bodies are working to develop standards and guidelines for LCAs, which may become appropriate tools for evaluating the relative environmental impacts among materials. It must be noted, however, that a consensus on how to conduct these assessments has yet to be developed. Until such time, it is inappropriate to make public claims regarding the comparative overall environmental performance of various products and materials based on LCAs.

Where claims on a specific environmental component of a product or a material's performance is contemplated, it is important that the evaluation be based on widely accepted LCA methods. The claim should also follow logically and clearly from the analysis conclusions. In addition, any information on which the LCA claim is based should be readily available to the public.

Safe - The word "SAFE" has broad implications that may inadvertently be perceived as relating to personal safety or security and should therefore not be used as part of an environmental claim.

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Absolute Claims / Representations

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Absolute Claims - An absolute claim or representation leaves no room for doubt. When used as part of a claim, some symbols and terms imply conditions that may not exist. In the absence of qualifying information, this type of claim will be interpreted to mean "100%".

Symbols - The use of any symbol or statement relating to recyclability, without a qualifying statement, will be interpreted to mean completely recyclable (100%), or universally recyclable.

EXAMPLES:

1. the recycled content symbol, either alone or with a vague statement such as "Printed on recycled paper," "Made from recycled paper" or "Made with recycled paper" creates the impression that the end product is made entirely from recycled paper, and will be interpreted as such.

2. an unqualified claim of recyclability may be justified in a market area for materials which have established deposit and return systems in place, such as beverage containers, and the returned containers are recycled. Such a system has the potential to collect all identified containers, effectively providing universal access to all purchasers in that market area.

3. descriptors such as "... Free" or "Contains No ..." are absolute in that they claim the total absence of the stated substance.

Möbius Loop - Because the two Möbius Loop recycling symbols are still not widely understood, it is recommended that the symbols always be used with explanatory text.

Slogans - If short slogans, catch phrases or symbols are used to indicate reduced environmental burden, and these do not clearly convey the intended message, then there should be further qualification in the claim to ensure that the message is clear and understandable.

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Source Reduction of Materials

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Source reduction is an important means of waste management, and one that is increasingly being used and talked about. Waste management principles in Canada identify source reduction as having the highest priority for managing waste and substances with high environmental impacts. The benefit of source reduction is derived from reduced levels of materials being used, and ultimately sent for disposal. For this reason, claims in this area must relate to the reduction of total materials, or reduced levels of toxicity.

Comparisons - There are many ways to reduce the amount of materials used, whether it is through eliminating the package, "lightweighting," using alternative materials or reformulating the product. Whichever method is used, however, claims of source reduction should be comparative claims. This means that any reference to reduction must be made relative to that product or package at a relevant predetermined reference point. Extreme caution should be used when making comparisons with competing products because any subsequent similar reduction in the competitor's product could make the comparison invalid resulting in a misleading claim.

EXAMPLE:

if a manufacturer changed the packaging of a product from a combination of inner wrap, outer box and cellophane (total weight 10 g) to a single box (weight 6 g), the claim could be "40% reduced from our previous package."

When making comparisons, it is important to ensure that the comparison is made for equivalent amounts of product.

EXAMPLE:

if comparing the relative benefit of packaging materials between two different products such as liquid and powdered laundry detergent, the comparison should be based on a common measure such as the number of uses, e.g. this product requires X% less packaging on a per use basis than product Y.

Distribution Reduction - Source reduction may also relate to the entire production and/or distribution system for the product.

EXAMPLE:

if a product or its container has not changed, but changes have been made in the distribution system to eliminate a significant amount of waste, such as using reusable pallets instead of single use pallets, then it may be appropriate to identify that initiative. It should, however, be very clear that the identified reduction has taken place in the distribution of the product and not the product or its container ("This product is now shipped from the factory on reusable pallets, resulting in an estimated waste reduction of XX tonnes per year").

Quantify - In all cases, claims of source reduction should include a quantified indication of the reduction.

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Reusable/Refillable Containers or Products

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Reuse opportunities - Many products and packages are reusable or refillable by consumers, and they are generally aware of that fact. It is important, therefore to identify new reuse opportunities that may not be readily apparent.

EXAMPLE:

glass, plastic and corrugated containers have generally been reusable by the consumer after the product has been consumed. To identify these containers as reusable for that reason alone may not be appropriate.

Infrastructure - There are many cases where a claim of reusability may be appropriate. The following examples are illustrative only and not meant to exclude other legitimate claims. In all cases, however, a reuse "infrastructure" must exist or facilities or products must exist that allow the end user to directly reuse or refill the item, and where it is not obvious, the claim must explain how the container or product is to be reused or refilled, e.g. with the purchase of a refill pouch, by returning for cleaning or restoration.

EXAMPLES:

1. the container can be reused/refilled for its original purpose without reprocessing beyond normal cleaning operations.

2. a product is supplied in a durable reusable container as well as a light-weight refill.

3. a product is reformulated to a concentrated version so that it can be packed in a smaller container, but would be reconstituted in a larger reusable container for normal use.

4. a manufacturer replaces the product packaging with a durable storage container such as might normally be found for sale at retail.

5. the design of a product is modified to facilitate restoring it to an "as new" condition for reuse, e.g. printer ribbons and toner cartridges, and the facilities exist for such restoration to occur.