Singapore Issues New Guide to Curb Greenwashing

Key Takeaways

• Applies broadly: The CCS guide covers all suppliers in Singapore, assessing not just wording but the overall impression of quality-related claims.
• Five guiding principles: Claims must be accurate, clear, meaningful, supported by credible evidence, and accompanied by material information.
• Certification and goals: Businesses must be precise about certification status and ensure aspirational claims, such as sustainability pledges, are backed by concrete steps and recognized measures.
• Accountability: Misleading or unsupported claims may amount to unfair practices under the CPFTA, exposing businesses to enforcement action and consumer complaints.

Deep Dive

The Competition and Consumer Commission of Singapore (CCS) has released a new Guide on Quality-Related Claims to help businesses ensure their marketing practices are clear, accurate, and backed by evidence. The move comes amid rising concerns over greenwashing and recent enforcement actions against misleading advertising.

The guide outlines five key principles that businesses should follow when making claims about the qualities, uses, or benefits of their products or services. These principles are aimed at reducing unfair trade practices under the Consumer Protection (Fair Trading) Act 2003 (CPFTA).

CCS said the guide was prompted by consumer complaints and instances where businesses overstated product benefits or misrepresented certifications. Misleading quality-related claims (QRCs), the agency warned, could amount to unfair practices under the CPFTA and lead to enforcement action.

Consumers who encounter questionable claims are encouraged to first seek assistance from the Consumers Association of Singapore (CASE) or, if the claims appear in advertisements, to report them to the Advertising Standards Authority of Singapore (ASAS).

Five Guiding Principles for Businesses

At the heart of the guide are five principles that businesses are expected to observe:

1. Truth and Accuracy: Claims must be factually correct, not exaggerated, and supported by verifiable data. For example, a company cannot claim a product meets an industry standard if only a single component does.
2. Clarity and Simplicity: Claims must be easy for the average consumer to understand, avoiding vague or technical language that could mislead. Businesses should also avoid using self-created labels that suggest third-party certification when none exists.
3. Meaningful Information: Businesses should focus on significant, non-standard product features rather than mandatory or trivial attributes. Comparative claims must be fair, specific, and substantiated.
4. Full Disclosure: Any limitations, assumptions, or conditions tied to a claim should be made clear. For instance, businesses cannot imply immediate environmental benefits if such outcomes only occur over time.
5. Evidence-Based: Claims must be backed by credible, up-to-date evidence such as certifications, scientific studies, or tests conducted by qualified experts. Outdated or expired certifications cannot be presented as current.

Enforcement Under the CPFTA

CCS emphasized that misleading quality-related claims, such as false endorsements, exaggerated environmental benefits, or unsubstantiated health claims, can be investigated and stopped under the CPFTA. When assessing cases, CCS will consider whether a business made reasonable efforts to verify its claims, taking into account its scale and resources.

While the guide offers practical direction, CCS noted it is not a substitute for the law. Businesses remain responsible for complying with the CPFTA as well as other sector-specific regulations. Suppliers uncertain about compliance are advised to seek legal counsel.

The guide also points businesses to the Singapore Code of Advertising Practice (SCAP), administered by ASAS, which requires that claims in advertisements be clearly explained, substantiated, and qualified.

CCS said it may update the guide over time to address emerging practices and risks, particularly as sustainability-related marketing and green claims continue to attract regulatory scrutiny.

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