Who: International Chamber of Commerce (ICC)
Where: Global
When: 13 November 2025
Law stated as at 26 November 2025
What happened:
As regulators worldwide continue to focus on green claims, the ICC, a global business organisation representing companies in more than 170 countries, has published the fifth edition of its Framework for Responsible Environmental Marketing Communications.
What is the framework?
The framework accompanies the ICC’s Advertising and Marketing Communications Code, which aims to support advertisers across different jurisdictions and minimise the need for legislative intervention. While the code sets out general principles for advertising, with chapter D setting out guidance on environmental marketing communications, the framework provides additional practical guidance on environmental claims.
The framework features an environmental claims checklist designed to assist advertisers in identifying whether claims are environmental in nature and in evaluating their clarity, substantiation and potential to mislead. It also provides a table that links the general provisions and chapter D of the ICC Code to additional practical considerations that businesses should think about in order to comply with the Code. The framework also provides guidance on a selection of specific environmental claims that have become common in the market, including “carbon neutral”, “circular” and “recyclable”, and explains how the ICC principles and other considerations apply to such claims.
Given that many environmental terms lack universally accepted definitions and regulatory approaches differ between jurisdictions, the framework deliberately avoids imposing fixed standards. Instead, it provides flexible guidance to accommodate these variations, with its core message being that all environmental claims must be appropriately substantiated with reliable, scientific evidence.
What’s in the latest edition?
The 2025 edition reorganises the framework to align it with changes made to the 2024 edition of the ICC Code. It also refines the guidance on specific claims and expands on some emerging areas.
Updates include an enhanced environmental claims checklist revamped to be more user-friendly, expanded guidance on environmental, social, and governance (ESG) claims and extended producer responsibility schemes. The framework also includes new guidance on making “bio-based” claims, recommending that advertisers make the source of the bio-based material and the limits of any environmental benefit clear to consumers.
Why this matters:
While the framework is a self-regulatory tool and not legally binding on UK advertisers, it is a helpful benchmark for assessing environmental claims and making sure that they are responsible. The ASA refers to the framework as being among the key resources available to marketers on green claims, saying that it provides a helpful approach for stakeholders to use in developing and analysing their environmental claims.
In this latest update, advertisers will particularly appreciate the revamped environmental claims checklist, which is now clearer and more user friendly, to stress-test proposed green claims.
