Ad Standards’ New Guidance on Environmental Claims – What Brand Owners Need to Know

Ad Standards recently released its Guidance on Environmental Claims in Advertising, on April 16, 2026, which provides guidance on how environmental or “green” claims, whether express or implied, may be assessed under the Canadian Code of Advertising Standards (the “Code”). The Advisory focuses on avoiding environmental claims that may be inaccurate, deceptive, or otherwise misleading, including where the overall impression of an advertisement overstates an environmental benefit or is not supported by competent and reliable evidence.

The Advisory follows the Competition Bureau’s (the “Bureau”) guidelines on environmental claims under the Competition Act, which addressed recent greenwashing amendments and the Bureau’s approach to claims about environmental benefits of products, services or operations. We have discussed this in our previous article: what brand owners need to know to avoid “greenwashing”.

While the Bureau’s guidance focuses on statutory compliance and enforcement, Ad Standards’ Advisory translates many of those principles into practical, advertising‑specific guidance under the Code, informed by recent complaint trends and adjudicated decisions. Together, the Bureau’s Guidelines and Ad Standards’ Advisory signal continued scrutiny of environmental and greenwashing marketing in Canada. 

For brand owners, the new Advisory does not introduce new legal tests under the Competition Act, but it does clarify how environmental claims may be assessed in advertising practice, and where greenwashing risk most commonly arises under the Code.

Key additions and clarifications for advertisers:

1. Overall impression now clearly includes imagery, colour, and sound
Ad Standards emphasizes that environmental claims may be conveyed not only through words, but also through visual and sensory elements, such as nature imagery, colour schemes associated with sustainability, and audio cues. Even where no express environmental claim is made, these elements may contribute to a misleading “green” impression unless substantiated.

2. Evidence must support both express and implied claims            Advertisers should have up-to-date, valid, reliable, and relevant scientific evidence to support all environmental claims, including implied claims. The evidence must support the full scope of the claim being made, not merely a narrower or related environmental benefit.

3. Third‑party certifications do not automatically support broad claims
The Advisory makes clear that certifications, sustainability commitments, or general environmental responsibility are not sufficient to substantiate broad or absolute claims such as “save the planet” or “carbon neutral.” Claims must not extend beyond what the evidence actually supports.

4. Broad and absolute environmental claims are especially high risk
Echoing the Competition Bureau’s guidance, Ad Standards cautions against unqualified claims such as “green,” “environmentally friendly,” “eco-safe,” “carbon friendly,” “sustainable,” and “climate smart.” Importantly, the Advisory highlights that such claims often imply net environmental benefit across a product’s or business’s lifecycle, triggering a very high evidentiary burden.

5. Environmental symbols, seals, and icons require care
The Advisory also cautions against using environmental signs, symbols, seals, or logos in a way that may mislead consumers. If a symbol suggests third-party approval or certification, the source should be clear, and the approval or certification must actually have been obtained.

6. Increased scrutiny of exaggeration and vague language
Ad Standards places particular emphasis on avoiding exaggeration. Even genuine environmental improvements must be described accurately and narrowly, without implying a greater impact than is supported by the evidence. Vague or open‑ended claims that invite multiple reasonable interpretations remain a key source of consumer complaints.

7. Qualifiers must be clear, close, and effective
Where qualifiers are necessary to prevent an environmental claim from being misleading, they must be clear, conspicuous, and placed close to the claim. The Advisory expressly notes that disclaimers delivered through links, QR codes, or separate webpages are insufficient, and that qualifiers cannot cure an otherwise misleading overall impression.

8. Forward‑looking and aspirational claims require substantiation
Ad Standards reinforces that aspirational claims—such as future environmental goals or targets—must be supported by realistic, evidence‑based plans and reasonable grounds. Aspirational messaging without credible substantiation may be treated as greenwashing.

9. Comparative claims may invite competitor disputes
Unlike the Bureau’s guidance, the Advisory highlights the risk of competitor‑initiated advertising disputes, particularly where comparative environmental claims are made. Comparisons must be fair, current, material, and based on comparable products or services in the Canadian market. Advertisers should also ensure that any claimed difference is meaningful and not overstated.

10. Practical insight from adjudicated cases
The Advisory includes illustrative Standards Council decisions involving “save the planet” and “carbon neutral” claims. These examples underscore how overly broad messaging and environmental imagery can create a misleading general impression, even where advertisers believe they are promoting environmental awareness or informed consumer choice.

What this means for brand owners

The Ad Standards Guidance on Environmental Claims in Advertising reinforces that environmental advertising is assessed through the lens of consumer perception, not advertiser intent.  Words, visuals, layout, and tone can all affect whether an advertisement creates an inaccurate, deceptive, or otherwise misleading overall impression. 

For brand owners, the practical message is clear: environmental claims must be specific, accurate, supported by competent and reliable evidence, properly qualified, and carefully executed to avoid greenwashing allegations under the Code, in addition to obligations under the Competition Act. Businesses should also maintain substantiation for their claims, as Ad Standards may require advertisers to disclose supporting evidence in response to a complaint or dispute.