Key considerations for members
A key message from the ACCC is that businesses need to consider the overall impression an emissions claim is likely to create for consumers. Claims should be supported by credible evidence and appropriate accounting methodologies, with businesses clearly explaining significant emissions sources that have not been included.
Importantly, information prepared for a particular emissions reporting regime may not necessarily support a broader environmental claim without further context. The ACCC notes that simply referring to figures from reporting schemes could be misleading if those figures exclude emissions that an ordinary and reasonable consumer would expect to be included. The guidance also highlights the need for transparency where carbon credits or certificates are used. Businesses should make clear where claims rely on credits rather than changes to their operations and ensure emissions benefits are not double counted.
For FTA/APSA members, these considerations may be relevant wherever emissions information is communicated through websites, tenders, customer information, marketing material or other external communications. While the ACCC is not an environmental regulator, it has responsibility for enforcing the Australian Consumer Law in relation to misleading claims. The ACCC also recognises that the level of due diligence reasonably undertaken may differ according to the size and resources of a business.
FTA/APSA encourages members responsible for emissions reporting, sustainability information and customer communications to review the new guidance and ensure any emissions claims are appropriately supported and clearly communicated.
Further Information
ACCC Media Release ACCC – Making emissions claims to consumers ACCC Guide |
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