Clearer Ground, Honest Claims: How Australia’s New Environmental Claims Code Changes the Rules for Marketers

From the moment a consumer reads “eco-friendly” or “carbon neutral,” they form expectations—spoken and unspoken—about what sits behind those words. For too long, many sustainability-related claims in marketing have hovered in the grey zone of vague language, partial truths, or implicit promises. On 1 March 2025, that zone contracted. The refreshed Environmental Claims Code, published by the Australian Association of National Advertisers (AANA), raises the bar—marketers now face stronger standards for truth, clarity and verification in environmental messaging. At TMFS, we believe this shift is not simply regulatory compliance; it is a redefinition of trust in brand-consumer relationships.

Central to the new Code is its insistence that any environmental claim be truthful and factual, clear and not vague, supported by evidence, reflect a genuine benefit, and when forecasting future environmental objectives, be based on reasonable grounds. info.aana.com.au+2wfanet.org+2 Claims must avoid sweeping, undefined language that misleads—terms like “green”, “eco”, “sustainable” or “climate friendly” are no longer safe unless clearly qualified. info.aana.com.au+1 Importantly, the Code aligns tightly with ACCC guidance and Australia’s broader consumer law framework—especially the Australian Competition and Consumer Law (ACL). DLA Piper+1

Real-world examples illuminate the implications. Under the old Code, a mining company’s advertisement claiming “clean gas” was ruled misleading: the term “clean” was broad, unqualified, and insufficiently supported. Under the new Code, such a claim would now clearly breach rules around clarity and evidence. Anisimoff+2info.aana.com.au+2 Marketers must now ask deeper questions: What is the product’s entire lifecycle? Which emissions are included? Is third-party certification genuine and up to date? Do statistics or test methods relate to conditions a consumer might actually experience? These are no longer optional considerations but core requirements. info.aana.com.au+1

Another major change is in scope. Environmental claims are no longer loosely defined. The Code explicitly covers any message, symbol, image, or representation (text, graphic, audio, symbolic) that implies a neutral or positive environmental impact, or that a product or service is “less harmful” than alternatives. Even packaging or images of labels displayed in advertisements now fall under the rules. info.aana.com.au+1 Previously, some claims fell through gaps because they weren’t classified clearly as “advertising”. Now the net is wider: more communications will be subject to scrutiny. wfanet.org

For marketers this presents both risk and opportunity. The risk is obvious: failure to comply can lead to complaints via Ad Standards, rulings by Ad Standards Community Panel, requirement to alter or remove content, and reputational damage. Anisimoff+1 More subtle risks include loss of consumer trust and exposure under consumer law (ACL) and possible ACCC involvement if misleading claims are found. DLA Piper+1

But opportunity also lies here. Brands that get this right stand to gain credibility, loyalty and competitive differentiation. Transparent, well-evidenced environmental storytelling resonates with consumers, employees, investors. Organisations able to demonstrate real environmental action—backed with data, certification and meaningful narrative—will lead the field rather than chase it. Navigating this change well can become a core strength. Marketing Mag

What must marketers do now to adapt and thrive under the new Code? First, audit all current environmental claims—advertising, packaging, digital content, labels—to ensure they meet the five new rules. If in doubt, revise or remove. Second, invest in internal sustainability literacy. Marketers, agencies, product teams must understand certification standards, life-cycle assessments, data sources, and risk thresholds. Third, establish processes for verification: maintain evidence files, test methods, supplier claims, independent certifications, and ensure they are up to date. Fourth, ensure clarity in communication: specify where, how, and under which conditions an environmental claim holds; avoid sweeping language; qualify where necessary. Fifth, prepare for transparency: if your sustainability goals are future-oriented, clearly articulate how you plan to meet them, track progress, and be open about challenges. info.aana.com.au+1

In closing, this new Environmental Claims Code marks a watershed moment. At TMFS we believe that as consumers become more discerning, they will reward honesty, precision, and accountability. Brands that lead with transparency will not only avoid legal and regulatory misstep but will help to restore public trust in sustainability claims industry-wide.

Let this be the moment when environmental marketing transcends superficial language and becomes rigorous, reliable storytelling. We invite marketing leaders, agencies, product teams and CEOs to not treat the Code as a limitation, but as a framework—a map to credible distinction. TMFS commits to guiding readers through this emerging landscape of sustainability and trust.

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