Sustainability.
If there was a word to sum up the focus of the entire packaging community in recent years, that would be it. However, this one seemingly simple word is deceptively complex. What is truly ‘sustainable’ packaging? Is it recyclable? Is it compostable? Is it plastic-free? Is it packaging that uses the fewest materials, or produces the fewest emissions through the supply chain? Or is it the pack that results in the smallest amount of waste?
These questions don’t always have concrete answers. And while ‘sustainability’ is useful as a broad umbrella term that describes a general desire to minimise our impact on the environment, it also contains a lot of ambiguity that the Green Claims Code aims to clarify.
What is the Green Claims Code?
The Green Claims Code is a set of guidance published by the UK’s Competition and Markets Authority (CMA). It is similar – although not to be confused with – the EU’s Green Claims Directive, in that it aims to clear up the confusion about sustainability claims and prevent ‘greenwashing’.
There are many ways to make packaging more sustainable, but these need to be communicated specifically and clearly to consumers. This prevents claims from being vague and, more importantly, helps ensure that they are accurate, helping consumers make more informed choices about the products they buy.
The Code applies to all retailers, distributors, manufacturers, and wholesalers operating in the UK.
Why do we need a Green Claims Code?
Study after study shows consumers generally support sustainable initiatives, but they need guidance and support to fully engage with them – half of consumers say they don’t have enough information to adopt a more sustainable lifestyle, according to Deloitte. If that guidance is vague or misleading, this can severely undermine efforts to reduce our impact on the environment, poisoning the well against genuine green claims and making consumers feel jaded at a time when we need to spread positivity around sustainable behaviours.
The average person doesn’t have the time or the inclination to study the fine details of the recycling stream and its many challenges, so when they see a lidded plastic tray that prominently claims to be recyclable, for example, they might reasonably assume every component is recyclable without checking for OPRL’s recycling symbols. The unfortunate result is that they end up dropping the recyclable tray with its non-recyclable lidding film into their recycling bin and potentially contaminate the recycling stream.
The six principles of the Green Claims Code
Before they make an environmental claim – either carried on-pack or on other marketing collateral – brands must make sure that claim passes six simple tests. Claims must:
1. Be truthful and accurate
This is fairly self-explanatory – don’t make misleading, exaggerated, or overstated claims about a product. For example, if a product is only partly recyclable, it isn’t accurate to describe it as ‘recyclable’. Explain clearly which components are suitable for recycling, and which components aren’t.
2. Be clear and unambiguous
Any claims made in product messaging shouldn’t give consumers a false impression of its green credentials. Vague claims like ‘green’, ‘sustainable’, and ‘eco-friendly’ aren’t useful when describing a product and should be avoided.
3. Not omit or hide important, relevant information
Consumers can’t make an informed choice about what product to buy if information is hidden from them. If including a stat from a consumer survey, for example, make sure to clearly communicate all the relevant details of that survey.
4. Make comparisons fair and meaningful
Any comparisons to other products or previous packaging solutions must be like-for-like. If a product claims it uses ‘60% less plastic’, explain what this comparison is based on and how it’s been calculated.
5. Consider the full life cycle of the product or service
Designing sustainable packaging is a complex balancing act. Swapping plastic packaging for a paper-based alternative is all well and good, but if that new pack doesn’t perform through the supply chain, it can lead to increased product waste, which in turn might mean it’s a net negative for the environment.
6. Be substantiated
Another self-explanatory point – claims, stats, and certifications must be supported by evidence, and this evidence must be accessible to consumers who choose to look for it.
What does the Green Claims Code mean for your business?
The Code represents both a challenge and an opportunity for companies in the packaging industry and the wider business community. It requires businesses to have a deep understanding of their supply chains, taking a more holistic view of a product’s whole life cycle to provide consumers with more clarity about its environmental credentials. This may require the investment of time and capital – particularly in cases where independent third parties must be brought in to provide audits.
And while there is no specific penalty for breaching the Code, failing to meet the six tests outlined above could mean businesses fall foul of consumer protection laws. The maximum penalty for doing so is a fine of 10% of global turnover, indicating that this issue is taken seriously by the CMA.
However, businesses that can ensure their green claims meet the new standards will be in a strong position to cut through the noise in a market where sustainable messaging is becoming the industry standard. By thinning out greenwashing claims, the businesses that can articulate clear, accurate, and verifiable environmental messaging will be the ones best placed to engage eco-conscious consumers.
It’s also an opportunity to raise awareness and education about the many nuances of sustainability, enabling more constructive industry conversations about the topic in the future. In light of the introduction of other environmental regulations, such as the continuing rollout of EPR, this can only be a good thing.
It means that a clear, expert communications strategy is invaluable for businesses that want to develop products and packaging that minimise their impact on the environment. At Think B2B, our team of packaging industry experts is on hand to support our clients through these changes, ensuring their messaging is heard by the people who matter most to them. And we’re here to support you, too – and reaching out is just a click away.
