Guidance on Environmental Claims in Advertising

Issued April 16, 2026

Overview

This Advisory was developed to provide guidance to the advertising industry to help ensure that environmental or ‘green’ claims, whether expressly stated or implied, comply with the provisions of the Canadian Code of Advertising Standards (the “Code”).

Advertisers rightly want to highlight the environmental benefits of their products or services in their marketing messages. This messaging, where it is truthful and complete, can be consistent with the Code and provide useful information for consumers to make wise choices that can be better for the environment. However, where such messaging directly or indirectly exaggerates environmental benefits, minimizes negative environmental impact, or is not based on competent and reliable evidence — a practice commonly referred to as ‘greenwashing’ — it can become a source of misinformation to consumers and can ultimately become subject to consumer complaints or competitor disputes for violation of the Code.

Tips for Advertisers

In order to avoid creating advertising with a general impression that could be considered misleading or deceptive under the Code, keep these tips in mind:

Both the actual language of your messaging and the general impression created in an ad (including through imagery and sound) must be accurate and truthful. This means that both the literal and implied meaning of the advertisement must be truthful. In some contexts, using colours that are suggestive of nature or imagery that includes elements of nature can be considered environmental claims, which can only be made where they are truthful and supported.

Make sure you have up-to-date valid, reliable and relevant scientific evidence to support all claims, both direct and implied. The data should reflect sound scientific principles that would likely be accepted by experts in the field.

Don’t exaggerate. Specificity and clarity are essential. Keep claims specific to the environmental benefit that is actually achieved by the product or service being advertised. Make sure claims being made are not broader than your supporting scientific evidence. This requires a careful reading of the evidence and ensuring that the claims made can be supported in their entirety. Include the specifics within the claim itself so that you do not exaggerate the benefits. The requirement not to exaggerate also means that you should not imply that an environmental benefit has a bigger impact than it actually does on the environment.

Avoid vague and non-specific claims that are subject to multiple interpretations. If there are multiple interpretations available to your claim, you will need to make sure that your evidence supports each of the possible, reasonable interpretations.

Broad claims require a very high standard of proof. Avoid making general or absolute claims without qualification, such as “environmentally friendly”, “eco-safe”, “green”, “carbon friendly”, “sustainable”, and “climate smart”. These general claims imply that the product or service has no impact (other than a positive impact) on the environment. And they may trigger the need for the advertiser to analyze the entire lifecycle of the product or service (i.e. from the time resources are extracted and processed through each stage of manufacturing, transportation, product use and disposal). Note that a general claim based on a single attribute is likely to be misleading unless the link is specific and clear.

Be cautious when using environmental signs or symbols. Do not use environmental signs or symbols unless the source of those signs and symbols is clearly indicated, and the official approval/certification has in fact been obtained. In addition, do not use environmental signs or symbols if there is a likelihood of confusion as to what these signs and symbols mean. For example, if consumers might reasonably believe that an advertiser’s own seal or logo indicates that a product has earned approval from an independent third-party, this would be misleading.

Don’t overstate environmental improvements. A meaningful improvement to a product or service does not automatically make it “good” or “better” for the environment overall. Claims should be limited to the specific improvement achieved (e.g., reduced emissions compared to a prior model) and should not imply a broader environmental benefit or net positive impact unless substantiated.

Use qualifiers properly. If a qualifier is needed to prevent a claim from being misleading, it must be clear, conspicuous, and placed in close proximity to the claim, so the claim and qualifier are read together. Linking to a website or using a QR code is not sufficient. Remember that qualifiers may provide additional context, but they cannot contradict or “cure” a misleading overall impression created by the main claim.

Use aspirational claims with caution. Even forward-looking environmental goals must be supported by evidence. Substantiate any stated targets or commitments with reasonable grounds, and ensure you have concrete, good-faith, realistic plans in place to achieve the claimed environmental outcomes within the stated timeframe.

Ensure that comparative claims are fair and do not unfairly discredit, disparage or attack a competitor’s product or service. If you are comparing the relative environmental impact of your product to a competitor’s product, make sure that you are comparing like products of the current models available in Canada (i.e. apples to apples), and that the difference in impact claimed in the advertisement is of actual consequence. In other words, do not exaggerate the nature or importance of competitive differences. Remember that a competitor can launch an advertising dispute for an alleged violation of the Code.

Application of the Canadian Code of Advertising Standards to Environmental Claims

Ad Standards receives an increasing number of consumer complaints related to environmental claims under the Code. When a complaint submitted to Ad Standards raises a Code concern involving an environmental claim, the complaint is adjudicated by the independent Standards Council (Council) under Clause 1 (Accuracy and Clarity). Generally, these claims are specifically considered under Clause 1(a) and 1(e), set out below:

Clause 1: Accuracy and Clarity

In assessing the truthfulness and accuracy of a message, advertising claim or representation under Clause 1 of the Code the concern is not with the intent of the sender or precise legality of the presentation. Rather the focus is on the message, claim or representation as received or perceived, i.e. the general impression conveyed by the advertisement.

Advertisements must not contain, or directly or by implication make, inaccurate, deceptive or otherwise misleading claims, statements, illustrations or representations.

(e) All advertising claims and representations must be supported by competent and reliable evidence, which the advertiser will disclose to Ad Standards upon its request. If the support on which an advertised claim or representation depends is test or survey data, such data must be reasonably competent and reliable, reflecting accepted principles of research design and execution that characterize the current state of the art. At the same time, however, such research should be economically and technically feasible, with regard to the various costs of doing business.

As set out in Interpretation Guideline #3, when evaluating complaints related to environmental claims that are allegedly misleading or deceptive under the Code, Council may, in exercising its judgment, take into account the guidance of the Competition Bureau and the ICC Framework for Responsible Environmental Marketing Communications 2025 edition.

Illustrative Standards Council Decisions

The following upheld cases offer helpful guidance on Council’s interpretation and application of Clauses 1(a) and 1(e) to environmental claims.

‘Save the planet’ claim

Council had the opportunity to review a broad ‘save the planet’ claim in the context of an ad for a product. The advertiser was of the view that because it had third-party certification for meeting various environmental standards, including a commitment to sustainability, and that environmental responsibility was central to their operations, the ‘save the planet’ claim was adequately substantiated.

Council unanimously found the claim ‘save the planet’ was misleading under Clause 1(a). Council was of the view that the third-party certification was not sufficient to support the broad claim and that the context of the ad did not provide any additional support or substantiation.

Council acknowledged the need for caution when making environmental claims. Specifically, it noted that care must be taken to avoid vague claims that may give consumers the impression that the environmental benefit is more extensive or meaningful than it actually is.

In addition, a majority of Council held that Clause 1(e) of the Code was contravened because the advertiser did not provide competent and reliable evidence to support the claim, notwithstanding that the advertiser provided the information that it relied upon to support its advertising.

Carbon neutral claim

In a separate case related to the use of broad claims, a complaint was made about an online ad that promoted the advertiser’s products using a voice-over encouraging viewers to choose their products because the company is carbon neutral, suggesting that doing so is good for the future, will make the planet better and help save the environment. The visuals of the ad included nature imagery.

In its response to Council, the advertiser advised that the advertisement sought to promote informed decision making and raise awareness about the carbon footprint associated with the production and consumption of products similar to its own and encouraged consumers to be mindful of the environmental consequences of their choices.

The majority of Council did not view the advertisement as a general broad message encouraging viewers to make informed choices that support their environmental values. Rather, Council viewed it as an advertisement that included strong environmental claims and was full of natural imagery that collectively exaggerated the environmental benefits of the product, creating the misleading impression, known as greenwashing. Those Council members found the general impression conveyed by the advertisement made a direct causal connection between using the advertiser’s products and achieving certain environment benefits.

A majority of Council held that the advertisement contained an inaccurate, deceptive or otherwise misleading representation in contravention of Clause 1(a) of the Code.