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Comparisons should enable consumers to make informed choices about competing products and businesses, or between different versions of the same product. They should not say or imply, through the use of language or imagery, that one product (or one version of a product) is, for example, ‘greener’ or ‘environmentally friendlier’ or ‘more energy efficient’ than another, if it is not.

Your business may make claims comparing your products with identifiable competitors’, or make comparisons between aspects of your own products (like old and new versions). Either way, the same considerations apply.

Comparative environmental claims should compare like with like. That means:

• Any products compared should meet the same needs or be intended for the same purpose, with a sufficient degree of interchangeability.
• The comparison should be between important, verifiable and representative features or aspects of the relevant products.
• The basis of the comparison, and the way it is presented, should allow consumers to make an informed decision about the relevant merits of one product over another.

For example, a claim which compares two similar products’ recyclable content, greenhouse gas emissions or organic composition, should calculate these measurements in the same way for each product. The values used to measure these comparisons, and the way they are presented, should be clear enough for consumers to understand.

In addition, the comparative claim should indicate how the information that forms the basis of the comparison can be accessed in order for the comparison to be verified for accuracy.

It is also important to ensure that a comparative claim is up to date and relevant. For example, where your claim compares a new product against an existing or previous one, you should carefully consider the appropriate period of time for which the claim can be made. A claim relating to a product’s ‘new and improved’ environmental credentials will have a limited shelf-life.

There are also similar rules applicable to comparative advertising made from business-to-business. Such advertising must only compare goods or services meeting the same needs or intended for the same purposes.

Checklist for fair and meaningful environmental claims

Before making a claim, you should ask yourself:

• Is the claim comparing like with like? 
• Is the like for like comparison a fair and representative one?
• Is the basis of the comparison fair and clear?