"It'll be renewable one day": the ACCC case about a promise, not a product

Most greenwashing stories are about something that isn't true today: a pack that isn't really recyclable, a fabric that isn't really organic. This one is different. The ACCC's case against Australian Gas Networks is about a sentence written in the future tense — and that is what makes it the most useful case for small businesses to understand.

What happened

On 26 June 2025, the ACCC announced it had launched Federal Court proceedings against Australian Gas Networks (AGN), one of the country's largest gas distribution businesses, over its "Love Gas" advertising campaign.¹

The ACCC alleges that four advertisements — run on free-to-air television, streaming services and YouTube during 2022 and 2023 — misled millions of consumers by representing that the gas AGN distributes to homes on its network will be renewable within a generation.¹

The ads themselves were gentle, warm and completely free of small print:

• A young girl and her father cook and warm the house with gas appliances.
• The story fast-forwards, showing her as an adult still using gas in her own home.
• Statements included that gas was "becoming renewable", that it was "for this generation and the next", closing on "love a renewable gas future".
• According to the ACCC, the advertisements contained no qualifications, fine print or disclaimers.¹

The ACCC's central allegation is not that renewable gas is impossible. It is that AGN did not have reasonable grounds for making an unqualified claim about the future of the gas in its network — while, the regulator says, it was aware of significant technical and economic uncertainty about whether renewable gas could be delivered to households at scale within that timeframe.¹

The ACCC is seeking declarations, pecuniary penalties, costs and other orders. An AGN spokesperson said the group was "disappointed" by the action and would defend the claims.²

These are allegations that have not been determined by the court. No penalty has been imposed. Australian Gas Networks is entitled to defend the proceedings, and nothing here should be read as a finding of contravention.

Why a claim about the future is still a claim today

Under the Australian Consumer Law there is a specific rule for this situation. Where a business makes a representation about a future matter and does not have reasonable grounds for making it, the representation is taken to be misleading — and the business, not the regulator, carries the burden of showing it had those grounds.³

In practice that flips the usual instinct. "We were only talking about our goal" is not a defence on its own. The question a court asks is what you had in your hands at the moment you published: the plan, the costings, the supplier commitments, the evidence that the trajectory was realistic.

The ACCC's environmental claims guidance says the same thing in plainer language: aspirational claims should be backed by reasonable grounds, and businesses should be clear and specific rather than leaving consumers to assume a target has already been reached.⁴

The four words that create the risk

Forward-looking sustainability language usually falls into one of a few patterns. These are the ones worth auditing on your own site:

• "Becoming" — "our packaging is becoming plastic-free". Becoming by when? What proportion is there now?
• "Working toward" — "we're working toward zero waste". Working how? A signed contract and a diverted-waste figure is a plan; an intention is not.
• "On our way to" — reads to most customers as "nearly there". If you're at 15%, say 15%.
• "Future-proofing" / "the next generation" — emotive, unmeasurable, and easy for a customer to hear as a promise about the product they're buying now.

For a skincare, candle or clothing brand, the AGN pattern maps across almost exactly: a warm story, a hopeful line about where the business is heading, and no qualification anywhere near it. The scale is different. The shape of the claim is identical.

How to write a future claim that holds up

Three rewrites, using the same information a small business already has:

• Before: "We're on our way to zero-waste packaging."
  After: "In 2026, 62% of our packaging by weight is home compostable. Our aim is 100% by the end of 2028 — the remaining component is the pump mechanism, which we're currently trialling alternatives for."
• Before: "Working toward a carbon neutral future."
  After: "We've measured our scope 1 and 2 emissions since 2024 and cut them 18%. We don't currently make a carbon neutral claim."
• Before: "Sustainable skincare for this generation and the next."
  After: "Refillable glass bottles, cold-processed formulas, and Australian-made — here's what each of those means."

The test is simple: a specific, dated, evidenced target with the current position stated. If the sentence can't survive a customer asking "how far along are you, exactly?", it needs work before it goes live.

Where this sits in the wider enforcement picture

AGN is one of several matters that show environmental claims are being actively litigated rather than quietly warned about:

• Clorox Australia — $8.25 million Federal Court penalty in April 2024 over misleading "ocean plastic" claims on GLAD bin liners.⁵
• Vanguard Investments Australia — $12.9 million ASIC penalty in September 2024 over misleading ESG exclusion claims.⁶
• Grill'd — Federal Court proceedings over the "Tree Day Tuesday" donation campaign.⁷

Misleading environmental and sustainability claims have been a stated ACCC compliance and enforcement priority every year since the regulator's December 2023 guidance was published.⁴

Frequently asked questions

Where to go from here

Related reading: the ACCC's case against Grill'd, is greenwashing illegal in Australia? and the ACCC's eight principles explained.

If your site contains any "working toward", "becoming" or "future" sustainability language, our free scan will flag the specific wording and the ACCC principle it engages.