Greenwashing Checklist For Product Packaging Claims

Priya runs a skincare brand in Melbourne. Her team is about to print 20,000 new product boxes with claims like eco friendly, plastic free and made from recycled materials. The packaging looks great, but one question keeps coming up: can they actually say all of this on the label?

It's a fair question. Sustainability claims can help customers choose your product, but vague or overstated wording can also create legal risk under the Australian Consumer Law.

The good news is that you don't need to avoid environmental claims altogether. You just need to make sure each claim is specific, accurate, supported by evidence and clear enough for a customer to understand.

What Counts As Greenwashing On Product Packaging?

Greenwashing can happen when your packaging gives customers an environmental impression that's false, misleading or not properly supported. It doesn't need to be intentional.

In Australia, environmental claims on packaging are mainly regulated under the Australian Consumer Law, which is Schedule 2 to the Competition and Consumer Act 2010. The Australian Competition and Consumer Commission, or ACCC, can take action where businesses make misleading claims about sustainability, recycling, carbon impact, materials or environmental benefits.

A packaging claim can be misleading because of:

• The words you use, such as green, eco friendly, sustainable or planet safe.
• The overall impression, including colours, leaves, earth imagery, badges or symbols.
• What you leave out, such as conditions, limits or disposal instructions.
• The evidence behind it, especially if you can't prove the claim when asked.

For example, if your box says 100% recyclable, but only the cardboard sleeve is widely recyclable and the plastic insert is not, the overall claim may be misleading. A better claim might say cardboard sleeve is recyclable where facilities exist. Remove plastic insert before recycling, if that's accurate for your packaging.

The practical risk isn't just a complaint from a customer. The ACCC can investigate, require corrective advertising, seek court orders and, in serious cases, pursue penalties. For corporations, maximum penalties for certain Australian Consumer Law breaches can be the greater of $50 million, three times the benefit obtained, or 30% of adjusted turnover during the breach turnover period. For individuals, penalties can be up to $2.5 million.

Can You Say Your Packaging Is Eco Friendly Or Sustainable?

You can use words like eco friendly or sustainable only if you can clearly explain what you mean and back it up with evidence. Broad claims are risky because customers may read them as saying the whole product has a low or positive environmental impact.

The ACCC has made it clear that broad environmental claims shouldn't be used unless they're properly qualified. This means your packaging should say what part of the product or packaging the claim applies to, and what environmental benefit you're claiming.

Instead of saying:

• Eco friendly packaging
• Better for the planet
• Sustainable choice
• Green product

Try to be more specific, such as:

• Outer carton made from 80% recycled paperboard
• Bottle made with 50% recycled PET
• Refill pouch uses 60% less plastic than our 500ml rigid bottle
• Certified home compostable mailer, excluding label

Specific wording is usually safer because it gives customers a clear basis for the claim. It also makes it easier for your business to keep records that prove the claim is true.

Be careful with comparisons too. If you say your packaging uses 60% less plastic, compared to what? Your previous packaging? A competitor product? An industry average? The comparison should be clear on the label, or close enough that a customer sees it before buying.

A useful rule is this: if a customer would need to guess what your claim means, rewrite it. If your marketing team would struggle to find the evidence in under 10 minutes, check the claim before printing.

What Evidence Do You Need For Environmental Claims Compliance?

You need evidence that directly supports the exact claim you're making. A supplier email saying this is green packaging usually won't be enough.

Your evidence should match the claim, the material, the percentage, the product batch and the country where the product is sold. The stronger and more specific the claim, the stronger your evidence should be.

Evidence To Keep On File

For packaging claims, useful evidence may include:

• Supplier specifications showing the materials used, including recycled content percentages.
• Certificates for compostability, recycled content, responsible sourcing or other recognised standards.
• Testing reports from credible laboratories, especially for compostable, biodegradable or plastic-free claims.
• Chain of custody documents if you're claiming certified paper, cardboard or forestry sourcing.
• Packaging composition records showing which parts of the pack the claim applies to.
• Internal calculations for reduction claims, such as plastic, weight or emissions comparisons.
• Artwork approvals showing who checked the claim before the label went to print.

Say Priya's skincare brand wants to print box made from 80% recycled paperboard on 20,000 cartons. Before approving the artwork, she should keep the paperboard supplier specification showing 80% recycled content, the product specification schedule or purchase order for that exact board, and an internal artwork approval note confirming the claim applies only to the box, not the jar, lid or label.

If the supplier later changes the paperboard to 60% recycled content, Priya needs a process to catch that before the next print run. Otherwise, the packaging may become inaccurate even if the claim was true when it was first approved.

How Long Should You Keep Evidence?

There's no single packaging evidence file rule under the Australian Consumer Law, but practically, you should keep records while the product is being sold and for a reasonable period afterwards. This helps if the ACCC, a retailer, a marketplace, or a customer asks you to substantiate the claim later.

Can You Claim Packaging Is Recyclable, Compostable Or Biodegradable?

It depends on whether the claim is true in practice, not just technically possible in a lab. Claims about end-of-life disposal are some of the easiest packaging claims to get wrong.

Recyclable Claims

If you say packaging is recyclable, customers may assume they can put it in their regular kerbside recycling bin. If that isn't true for most customers, you should qualify the claim.

Think about:

• Whether each packaging component is recyclable, such as the box, tray, film, cap, pump or label.
• Whether the components need to be separated first.
• Whether recycling facilities are widely available in Australia.
• Whether the colour, coating, adhesive or food residue affects recyclability.
• Whether you're using a recognised labelling system, such as the Australasian Recycling Label, where appropriate.

For example, recyclable packaging may be too broad if only the cardboard box is recyclable. More accurate wording might be recycle carton. Dispose of soft plastic wrap as directed by your local council, if that matches the packaging and current disposal options.

Compostable Claims

Compostable claims should explain whether the item is home compostable or industrially compostable. These aren't the same thing.

In Australia, recognised compostability standards include AS 4736 for industrial composting and AS 5810 for home composting. If you use a certification logo or claim, check that the certificate covers the exact packaging item, not just the raw material.

A claim like compostable pouch may mislead customers if it only breaks down in an industrial composting facility and those facilities aren't easily available to your customers. A clearer claim may say industrially compostable where accepted by local facilities.

Biodegradable Claims

Biodegradable claims are often high risk because they can suggest the item will safely break down in ordinary conditions within a reasonable time. If your packaging needs special conditions, high heat, oxygen or a long timeframe, say so.

If you can't explain where, how and when the item biodegrades, it's usually better to avoid the claim.

What Should Your Greenwashing Checklist For Australia Include?

Your checklist should test the claim, the evidence, the customer impression and the final packaging artwork before anything goes to print. This doesn't have to slow your business down if you build it into your normal packaging approval process.

Packaging Claim Review Checklist

• Identify every claim: list words, icons, colours, certifications, badges and disposal instructions that create an environmental impression.
• Break the claim down: write what the claim means in plain English and which part of the product or packaging it applies to.
• Check the evidence: match each claim to a supplier document, supplier agreement, certificate, test report or calculation.
• Check the scope: make sure the claim isn't broader than the evidence. If the evidence covers the carton only, don't make a whole-pack claim.
• Check the conditions: add qualifications if customers need to remove parts, access certain facilities, or follow special disposal steps.
• Check comparisons: explain the baseline for claims like less plastic, lower emissions or reduced waste.
• Check expiry and changes: confirm certificates are current and supplier materials haven't changed.
• Check the whole impression: look at the packaging as a customer would, not just line by line.
• Record approval: keep a short note of who approved the claim, when, and what evidence they relied on.

Fill-In Outline For A Packaging Claims Register

A simple claims register can help you stay organised. A lawyer should tailor it before you rely on it as part of your compliance process, but a useful outline includes:

1. Product name and SKU: identify the exact product and packaging version.
2. Claim wording: paste the exact words from the packaging artwork.
3. Claim type: note whether it's recycled content, recyclable, compostable, carbon, plastic reduction, sourcing or another claim.
4. Packaging component: state whether the claim applies to the carton, bottle, cap, label, insert, mailer or whole pack.
5. Evidence relied on: list the certificate, supplier specification, test report or calculation.
6. Qualifications needed: write any disclaimer or condition that must appear near the claim.
7. Approval details: record the date, approver and artwork version.
8. Review date: set a date to check whether the evidence or supplier material has changed.

This kind of record is especially useful if you sell through supermarkets, pharmacies, online marketplaces or major retailers under customer contracts, because they may ask you to substantiate claims quickly.

What Disclaimers Should You Put On Packaging Claims?

You should use disclaimers where they genuinely clarify a claim, but they can't fix a claim that's false or too broad. A disclaimer works best when it's clear, close to the claim and easy to read.

A common mistake is putting a bold claim on the front of pack, then hiding the limits in tiny text on the back. If the front says plastic free, but the label, seal or cap contains plastic, small print may not be enough to correct the impression.

Good Disclaimers Are Specific

Helpful disclaimers might say:

• Outer carton only
• Excludes cap and label
• Recycle carton. Check local council guidance for film
• Compared with our previous 500ml bottle, based on packaging weight
• Certified industrially compostable to AS 4736. Facilities may not be available in all areas

Less helpful disclaimers include vague phrases like conditions apply or where possible. These don't usually tell customers what they need to know.

Where To Place The Disclaimer

Place the disclaimer close to the claim where possible. If space is tight, use a short front-of-pack qualifier and more detail elsewhere on the pack.

For example, if the front says made with recycled plastic, the same panel might say bottle contains 50% recycled PET. Cap and label excluded. That's much clearer than a broad claim on the front and a technical explanation hidden under the base.

Also check that your website, social media ads, marketplace listing and wholesale sell sheet use the same claim. If the packaging is careful but the online listing says 100% sustainable packaging, your overall marketing may still create a problem.

How Do You Review Packaging Copy Before Printing?

You review packaging copy by treating environmental claims as a legal and evidence check, not just a design approval. The best time to do this is before you pay for plates, print runs or retailer approvals.

Here is a practical step-by-step process:

1. Collect the final artwork: review the actual pack, including front, back, sides, icons, QR codes and inserts.
2. Highlight every environmental impression: include words, symbols, colours and certification logos.
3. Ask what a reasonable customer would think: focus on the overall impression, not just technical accuracy.
4. Match each claim to evidence: if there's no evidence, remove or rewrite the claim.
5. Tighten vague wording: replace broad claims with specific, measurable wording where possible.
6. Add clear qualifications: state limits, exclusions and disposal instructions close to the claim.
7. Check consistency across channels: align packaging, website copy, advertising claims, retailer listings and sales materials.
8. Record approval before printing: keep the final artwork, evidence file and approval note together.

Here is how this can work in practice.

Mike runs a Brisbane coffee brand and wants to print 100% compostable coffee bags on a new run of 10,000 bags. His supplier certificate only covers the plant-based film to an industrial composting standard. The zipper and valve aren't covered, and home composting hasn't been tested.

Printing 100% compostable would be risky. A safer version might be bag film is certified industrially compostable to AS 4736. Remove valve and zipper before composting where facilities accept this packaging, assuming that's accurate. It's less punchy, but it's much more defensible.

If your claim depends on technical testing, certification or changing recycling infrastructure, get tailored advice before printing at scale. A packaging mistake can be expensive to correct once products are already in warehouses or on shelves.

Key Takeaways

• Environmental packaging claims must be accurate, clear and supported by evidence under the Australian Consumer Law.
• Broad words like eco friendly, sustainable and green are risky unless you explain exactly what they mean.
• Claims about recyclable, compostable or biodegradable packaging should explain the conditions, limits and packaging components involved.
• Keep a claims register with the exact wording, evidence, qualifications, approval date and review date.
• Disclaimers should sit close to the claim and clarify it. They can't rescue a claim that's false or misleading.
• Review packaging, website copy, ads and retailer listings together so your sustainability messaging stays consistent.

If you'd like help with reviewing your packaging claims, preparing a claims register, checking your disclaimers or updating your advertising terms, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.