Retailer Green Claims Forum: Waste, Packaging & Circularity
Last week, the BRC hosted the second session of the BRC and Provenance Retailer Green Claims Forum. Read on for a full summary of the session.
About the Retailer Green Claims Forum
With increasing legislation on green claims across the UK and EU, the BRC and Provenance Retailer Green Claims Forum aims to facilitate structured collaboration between retailers and sustainability leaders to address the issues and opportunities in communicating about sustainability in a compliant way. The forum will provide a platform to examine current approaches to brand- and product-level green claims, explore industry best practice when communicating about sustainability, and create open-source data standards for compliant green claims.
Session 2: Waste, Packaging & Circularity
Green claims regulatory updates
- Advertising Standards Agency (ASA) has published guidance on ‘regenerative agriculture’ claims. Key recommendations include to ensure transparency by providing clarity around statistics, and to avoid tokenism, absolutism, exaggeration and misleading comparisons.
- Through the Digital Markets Competition and Consumer (DMCC) Act UK the CMA will be empowered to impose fines on companies in breach of up to 10% of global revenue.
- The adoption and implementation of the first working plan for the EU Ecodesign for Sustainable Products Regulation (ESPR) will occur in April 2025. The plan will list products subject to eco-design requirements, likely to include metals, textiles, furniture and electronics.
- Green Claims Directive (EU) adopted by the European Parliament & Council by mid-2025. Enforcement is due from 2027.
WRAP’s Circular Living Standards
WRAP provided an overview of their work, in partnership with Amazon, to create the credible 3rd party Circular Living Standards and certification scheme. The launch will begin with four Standards:
- Preloved certified
- Reusable certified
- Refillable certified
- Durable certified
Certification through the Circular Living Standards would provide key benefits for businesses to:
- Stand out in a competitive market to increase sales and build brand reputation.
- Meet green claims compliance, with products verified to be usable in ways that reduce environmental impact, eliminate waste and maximise resource efficiency, as claimed.
- Meet consumer demand for sustainable products and give consumers confidence that a product’s sustainability claims are verified.
Discussion on packaging green claims
Recycled and recyclable claims
- Avoid absolute claims unless substantiated; state the specific percentages of recycled content and be clear about the recycled material used.
- Be specific on the components of the product that are recyclable, including guidance for consumers on how to recycle (e.g., through kerbside recycling or via take-back schemes).
Refillable claims
- State clearly which component is refillable and whether it is recyclable.
- Be clear about how accessible it is for the consumer to refill. A meeting poll indicated that a refillable scheme is considered most credible when it is easy for the consumer to refill using the infrastructure in place.
- Refillables and the level of environmental impact they need to have is before a claim should be made currently remains an area of uncertainty.
Circularity claims
- A meeting poll indicated that the majority believe ‘circular’ claims are impactful, but a common or organisational definition for ‘circular’ must be used.
- Be clear on what aspect of the product contributes to a circular economy, such as its repairability or reusability.
- Complete a full life cycle assessment (LCA) of the product.
Next steps
We’re translating the outputs of our discussion into realistic and compliant examples of green marketing claims for: recycled content, recyclability, refillable products and circular economy products. Once these have been reviewed and validated as accurate, we’ll publish here for your reference.
The Retailer Green Claims Forum is quarterly, with the next session planned for April 2025 – details to be announced soon. Please contact Tracey Banks if you have any questions about or are interested in joining the next forum.
