Examples of Competition Bureau guidelines for self-declared claims
Claims of “… free”
(For example: CFCs-free, Chlorine-free, alcohol-free)
Substance “free” claims need to be literally true, and cannot convey a general impression that is false or misleading.
Example: aerosol containers that promote they are CFC-free despite the fact that CFCs have been legally banned for more than 30 years and that all aerosols are CFC-free. It’s a claim that is true, but doesn’t reveal a useful environmental distinction between products.3 This could be considered misleading.
Example: a claim that a product is free of a certain chemical and is safe for the environment but fails to disclose that it contains a different harmful chemical, could be considered deceptive. [Guidelines p. 11]
Claims of “Sustainable”
Sustainability can be measured only over a very long period and there are no definitive methods for measuring sustainability or confirming its accomplishment at this time. Therefore, no claim of achieving sustainability should be made. Claims that refer to specific, registered management systems are sometimes acceptable provided that they can be verified.
Example: This wood comes from a forest that was certified to a sustainable forest management standard [i.e., a sustainable forest management standard published by the Canadian Standards Association, Sustainable Forestry Initiative (SFI), Forest Stewardship Council (FSC), or the Programme for the Endorsement of Forest Certification schemes (PEFC). [Guidelines p. 11-12]
Claims of “Compostable”
“Compostable” claims would be appropriate on products or packages that will break down or become part of usable compost in a safe and timely manner. For composting, a timely manner is approximately the same time it takes for composting organic compounds like leaves, grass, and food. Compostability claims should indicate if it is suitable for home composting or limited to municipal composting programs, whether all or part of the product is compostable, if there are any risks to composting the product, and should be qualified if facilities are not available to a reasonable proportion4 of purchasers, potential purchasers and users. [Guidelines p. 32-34]
Claims of “Degradable”
The term “degradable” refers to a characteristic of a product or packaging that, with respect to specific conditions, allows it to break down to a specific extent within a certain time [CAN/CSA-ISO 14021, Clause 7.3.1: Guidelines p.35]. This includes all types of degradability, such as photodegradability and biodegradability. Degradability claims should be supported by proper scientific testing, incorporate a reasonable timeframe and consider how consumers are likely to dispose of the product. A claim that a product is biodegradable should be made only if it would be true in the circumstances in which the product is likely to be disposed of and if no substances are released in concentrations harmful to the environment.
Biodegradable products destined for landfill should not make such claims due to degradability limitations, as most substances need light or oxygen to degrade, neither of which is available if the product is placed in a landfill. [Guidelines p. 36]
Example: Biodegradable claims for products that go down the drain, like shampoos/body washes or detergents, should be supported with tests that prove the product degrades in wastewater treatment systems. [Guidelines p. 36]
Claims of “Recyclable" and "Recycled Content"
Recyclable claims are only appropriate for products, packaging or associated components that can be diverted from the waste stream and collected, processed and returned to use in the form of raw materials or products. If collection programs or drop-off facilities are not conveniently available to a reasonable proportion of purchasers, potential purchasers and users, then qualified claims conveying the limited availability of collection facilities must be used. Generalized qualifications, such as “Recyclable where facilities exist” are not adequate.
Example: This container is recyclable through the blue box program in Southern Ontario and at recycling depots in Winnipeg and Edmonton [Guidelines p. 43]
Recycled content refers to the proportion (by mass) of recycled material in a product or packaging. Only material diverted from the waste stream during manufacturing (pre-consumer material5) and from consumer and other commercial, institutional end-users (post-consumer materials) can be considered as recycled content. The percentage of recycled content can be expressed as a written statement, or as a numerical percentage in the Mobius loop or immediately adjacent to the symbol. [Guidelines p. 25, 42, 44-46]
This product is made of 30% recycled content and is recyclable.
The Mobius loop6 should only be used for claims of recycled content and claims of recyclability. When the Mobius loop is used to claim “recycled content”, the percentage of recycled content must be identified in order to avoid the impression that the symbol refers to the recyclability of a product. Mobius loops used to designate both recyclability and recycled content simultaneously must be accompanied by an explanatory statement supporting both claims.
The Mobius loop may apply to the product or the packaging. However, if there is any potential for confusion about whether it applies to the product or the packaging, the symbol should be accompanied by an explanatory statement.
Comparative claims (for example, either between competing products, or between “new” versus “old” versions) must be accurate and verifiable, and always require an explanatory statement that is clear and precise about the nature of the extent of the improvement and the basis for the comparison.
Example: A statement such as “This product uses less energy” is not clear enough. “This product uses 20% less energy than our previous model” would be an appropriate way to make such a claim. [Guidelines p.29-30]
Environmental claims that are vague or nonspecific, or which broadly imply that a product is environmentally beneficial or environmentally benign, should not be used unless they are accompanied by statements that provide support for the claim. Claims that are vague or of a general nature, such as “safe for the environment” or “non-polluting” also require more comprehensive proof than fact-specific claims, such as “contains no chlorine”. Claims such as “environmentally friendly”, “ecological (eco)”, and “green” are examples of vague claims and should be reserved for products/services whose life cycles have been thoroughly examined and verified.
Example: “This product is ozone-friendly” is too vague.
“This product has replaced its aerosol ingredients with an alternative that does less harm to the ozone layer” would be preferable. [Guidelines p. 9-10 and 14-15]
4 If limited to municipal composting programs, at least half the population has access to collection facilities. Canadian Standards Association: Environmental claims: A guide for industry and advertisers p. 31 (Return to text)
5 Pre-consumer material is material diverted from the waste stream during a manufacturing process. Excluded is reutilization of materials such as rework, regrind or scrap generated in a process and capable of being reclaimed within the same process that generated it. This requirement is designed to limit the claim to material that has been deliberately collected and returned to an off-site producer for reclamation. (Return to text)
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