Greenwashing Risks in Packaging: How to Make Substantiated Environmental Claims

There was a time when a green leaf icon and the word "eco-friendly" printed on a box were considered savvy marketing. Those days are unequivocally over.

In the current Australian and New Zealand market, sustainability claims are under intense scrutiny. This pressure is coming from two directions: a cynical public that is tired of empty promises and regulators -specifically the Australian Competition & Consumer Commission (ACCC)- who have made "greenwashing" a top enforcement priority.

In my work auditing packaging artwork for FMCG brands, I often see well-intentioned businesses walking a compliance tightrope. They want to tell their sustainability story, but they lack the technical evidence to back it up.

The risks here are substantial. Beyond the financial penalties (which can be significant), the reputational damage of being publicly named for misleading consumers can destroy brand trust overnight. This guide outlines the strategic principles for making environmental claims that are not just compelling, but compliant.

The golden rule of avoiding greenwashing is simple: Do not say it if you cannot prove it.

The ACCC’s guidance is clear. Any environmental claim made on packaging must be accurate, specific and substantiated by evidence. "Puffery" -exaggerated marketing language- is no longer an acceptable defence when it comes to environmental impact.

Here are the three most common traps businesses fall into and how to avoid them.

• The Risk: What does "Eco-Friendly" actually mean? Does it mean the package is recyclable? Does it mean it was made with renewable energy? Or does it simply mean it is green in colour? Because these terms have no standard definition, they are inherently misleading to consumers.

• The Strategic Fix: Be specific. Replace broad adjectives with factual descriptions. Instead of "Eco-Friendly," say "Made from 100% Recycled Cardboard." Instead of "Green Choice," say "Recyclable in Kerbside Bins." Specificity builds trust and removes ambiguity.

• The Risk: A classic example is a "biodegradable" plastic bag. A brand might claim it is "Plastic Free" or "Earth Friendly" because it breaks down. However, if that bag requires industrial composting conditions that do not exist in most councils and it acts as a contaminant if put in the recycling bin, the claim is misleading. The "benefit" is outweighed by the practical reality of its disposal.

• The Strategic Fix: Consider the full lifecycle. Ensure your claim reflects the realistic end-of-life outcome for the majority of consumers. If a product is only recyclable in store drop-off systems (like soft plastics), you must make that clear rather than imply it is kerbside recyclable.

• The Risk: Using imagery that implies a third-party endorsement or a natural benefit that does not exist. This includes using "fake" certification logos (e.g., a green tick that looks like a government seal but is actually just a graphic design element) or imagery of leaves and forests on a product containing harmful chemicals or non-recyclable materials.

• The Strategic Fix: Only use recognised, third-party certification logos such as the Australasian Recycling Label (ARL), the Forest Stewardship Council (FSC) tree or the Australasian Bioplastics Association (ABA) seedling. These logos carry weight because they are backed by rigorous standards.

Before approving any artwork, I advise clients to run their packaging through this four-point checklist:

By moving away from vague marketing spin and embracing precise, evidence-based communication, you protect your business from regulatory wrath. More importantly, you build a relationship with your customer based on transparency. In the long run, being trusted is far more profitable than being "green."