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Comms Declare has responded to the Australian Association of National Advertisers (AANA) draft Environmental Claims Code, which is designed to stamp out greenwashing amid growing consumer complaints.

Comms Declare Founder, Belinda Noble said: “We congratulate the AANA on expanding the Code to include high emissions industries, as well as misleading environmental imagery and industry-wide greenwashing. These measures should prevent coal companies or the gas industry, for example, from advertising themselves as being sustainable or green.

“There are some items that we hope will be prevented in the final draft, such as net zero claims that are based on the highly contested use of offsets, or unproven technologies such as carbon capture – both of which are possible under this version.

“The draft code falls short of some overseas regulations on environmental responsibility grounds, which recently saw Toyota ads restricted in the UK.” added Noble.


  • Definition of an Environmental Claim is expanded to include businesses and whole industries (rather than just products) as well as images and graphics.
  • Says environmental claims must be supported by evidence.
  • Notes that leaving out important information is misleading.
  • Says small print cannot conflict with overall claim.
  • Broad claims should not be used without qualification.
  • For the first time, it warned high emissions industries, such as fossil fuels, against making broad environmental claims, noting the ‘overall environmental detriment of these industries’.
  • Says ‘aspirational targets’ need to be clear and achievable with realistic and verifiable plans.

Needs improving

  • Did not expand the audience to include all possible consumers – but only the ‘target audience’ of the ads.
  • Does not require that evidence to back up an environmental claim is publicly available when the ad is run.
  • Does not prevent the use of highly contentious offsets or technologies such as Carbon Capture and Storage to be the basis of environmental claims – because they may be available in the future.
  • Does not allow subject matter experts to join the Ad Standards Community Panel or advise on complex climate matters.
  • Falls short of UK guidelines that stipulate that advertising should not “encourage behaviour grossly prejudicial to the protection of the environment’.

Submissions should be made to before 22 March 2024.