How to avoid greenwashing in your marketing: a practical guide for Australian businesses

Why greenwashing usually happens by accident

Most Australian businesses that get flagged for greenwashing did not set out to mislead anyone. The claim was written quickly, nobody with the underlying facts reviewed it, and the person who signed off did not know what to look for. By the time a customer, competitor or the ACCC raises it, the copy has already been on the website for months.

A short, repeatable internal review process fixes almost all of that. This guide lays one out — a five-step workflow, a claim-approval checklist mapped to the ACCC's eight principles, and rewrite examples you can adapt.¹²

The five-step workflow

Treat every environmental claim the same way you would treat a pricing claim or a safety claim — as a factual statement that needs an owner, evidence and sign-off before it is published.

Step 1 — Draft the claim in writing

Write the exact words that will appear, including any qualifier and the surface they will appear on (home page hero, product page, packaging, social ad, email subject line). "Sustainable" on a hero image and "sustainable" in a paragraph of body copy carry different weight, because the hero image is what a customer sees first and remembers.

Step 2 — Identify the underlying fact

For every claim, name the specific fact it relies on. "Made with recycled content" is a claim; "the outer sleeve is 80% post-consumer recycled paperboard by weight, certified by supplier X" is the underlying fact. If you cannot state the underlying fact in one sentence with numbers, the claim is not ready.

Step 3 — Attach the evidence

Save the evidence in a shared folder alongside the claim: a supplier certificate, a life-cycle assessment, a Climate Active certification, an Australasian Recycling Label check, a test report, or the ATO/AUSTRAC-style paper trail for a certification body. The rule of thumb: if the ACCC asked for substantiation tomorrow, you should be able to send it the same day.²

Step 4 — Run the approval checklist

A second person — not the drafter — walks the claim through the checklist below. This is the most important control. Solo review by the person who wrote the copy rarely catches vague language or missing qualifiers, because the drafter already knows what they meant.

Step 5 — Publish, log and review

When the claim goes live, record the date, the surface, the exact wording and a link to the evidence folder. Set a review date — annually at minimum, sooner for claims tied to specific certifications, supplier contracts or offset purchases that expire.

The claim-approval checklist

This checklist is written directly from the ACCC's eight principles for trustworthy environmental claims.² Every claim should get a yes on every item before it is approved.

1. Truthful and accurate. Is the claim factually correct as written, right now? If a factual detail changed since the last review, the claim needs updating.
2. Evidence on file. Is there a document, test result or certification saved that a reasonable regulator would accept as substantiation?
3. Plain language. Would an average customer read the claim the same way we mean it? Vague words like "eco-friendly", "green", "sustainable" or "planet-friendly" without a specific qualifier are the single biggest risk.
4. Nothing important hidden. Are any qualifiers, exclusions or limitations displayed with the same prominence as the headline claim — not buried in a footnote or a separate page?
5. Whole-of-life honesty. Does the claim accurately represent the product's total environmental impact, or does it emphasise one small feature while a larger impact goes unmentioned?
6. Comparisons are fair. If we say "more sustainable than…", is the comparator identified, the basis specified, and the method consistent?
7. Trust marks are legitimate. Any logo, badge or certification used is real, current, and applies to this product — not a generic leaf icon designed to look like a certification.
8. Future claims are conditional. Aspirational claims ("carbon neutral by 2030", "on our way to net zero") name the target, describe the pathway, and are clearly future tense — not a present-day claim.

Rewrite examples

How the checklist changes real copy. These are illustrative; substitute the specifics your evidence actually supports.

Vague hero claim

Before: "Sustainable skincare for a better planet."

After: "Our bottles are made from 100% post-consumer recycled plastic (certified by [supplier]) and are refillable at our Sydney store."

The rewrite is specific, evidenced and describes a defined action. It survives the "would a reasonable customer read it the same way we mean it" test.

Unqualified carbon claim

Before: "Carbon neutral delivery."

After: "Delivery emissions offset through [certified program]. Certification details available on request."

For a full "carbon neutral" claim on the business as a whole, see our carbon neutral claims guide. The ACCC has said carbon claims without disclosed methodology and scope are a high-risk area.³

Packaging claim without a qualifier

Before: "Recyclable packaging."

After: "Outer box: kerbside recyclable across Australia (paper stream). Inner sleeve: check locally — recyclable at soft-plastic drop-off points."

The rewrite matches what a real customer can actually do with each component. For the full framework, see our recyclable packaging claims guide and the compostable/plastic-free deep dive on packaging language.

Aspirational claim written in the present tense

Before: "We are a zero-waste business."

After: "We are working toward zero waste to landfill by 2028. In 2025 we diverted 62% of our operational waste; our roadmap is published at [link]."

Where most small businesses slip up

The ACCC's 2023 internet sweep of 247 businesses across eight sectors found more than half of the environmental claims reviewed raised concern. The most common issues were vague and unqualified language, absent substantiation, exaggerated benefits, and confusing use of trust marks.⁴ The recurring pattern in enforcement outcomes has been the same categories of problem — see our summary of small business ACCC enforcement risk.

For a website-focused view of the same categories, our post on the five website patterns that attract ACCC attention is a shorter companion read.

Roles and sign-off for a small team

You do not need a legal department. A small business can run this workflow with three roles, one of which is often the owner:

• Drafter — writes the claim and identifies the underlying fact. Usually a marketer, founder or contractor.
• Fact owner — confirms the underlying fact from operations, product or supply-chain records, and attaches evidence.
• Approver — walks the claim through the eight-point checklist and signs off. Should not be the drafter.

For higher-risk claims — "carbon neutral", "net zero", "plastic-free", "100% recycled", "Australian made" with imported components — add legal review before publishing. The ACCC has repeatedly flagged those as priority language.³⁵

Keeping the workflow alive

A review process that is written down but not followed catches nothing. Three things make it stick in a small business:

• A single shared folder or tool where every live claim, its evidence and its review date is recorded — treat it the same as your invoicing records.
• A recurring calendar reminder to run the checklist over anything that has changed on the website in the last quarter.
• A rule that no environmental claim goes live without a named approver — the same discipline you would apply to a price change or a warranty statement.

Frequently asked questions

The bottom line

Avoiding greenwashing is not about avoiding the topic — customers actively want to know what a business is doing. It is about making sure every claim is specific, evidenced, plainly worded and reviewed by someone other than the person who wrote it. A short internal workflow, run consistently, catches the issues that cause almost every ACCC and public-relations problem before they reach a customer.