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Guidelines 5–10 of the Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024, with the guidance note: substantiation, disclosures and aspirational claims

Generic words such as 'clean', 'green', 'eco-friendly', 'sustainable' and 'natural' may not be used without adequate, accurate and accessible qualifiers, substantiation and...

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Published
October 3, 2026
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Oct 3, 2026
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Last updated: October 2026Verified against: Government sources

Guidelines 5 to 10 tell a business what it must do to make an environmental claim lawfully: avoid generic terms unless qualified and substantiated, explain technical terms in plain language, back every claim with verifiable evidence, disclose all material information (including through a QR code or URL), make comparisons on verifiable data, and make future-looking claims only with an actionable plan. Annexure-I, a guidance note, adds six areas of guidance with illustrations.

The guidelines were issued by the Central Consumer Protection Authority (CCPA) in 2024 and operate in furtherance of the 2022 guidelines on misleading advertisements. This article takes them as amended up to 3 October 2026 (no amendment listed by the CCPA). Later amendments should be checked on the CCPA website. The definitions and prohibition are in the article on guidelines 1 to 4. Consequences follow under the Act (guideline 10); this article quotes no penalty.

Brands, packaging teams and agencies that need an evidence file for their claims can ask for compliance advisory support on what to keep and how to disclose it.

Guideline 5: substantiation of environmental claims

All advertisements making environmental claims shall comply with three obligations.

  1. Generic terms (5(a)). Terms such as "clean", "green", "eco-friendly", "eco-consciousness", "good for the planet", "minimal impact", "carbon-neutral", "natural", "organic", "pure", sustainable, regenerative "or other similar claims" shall not be used "without adequate, accurate and accessible qualifiers and substantiation and adequate disclosure as provided under clause (6)".
  2. Technical terms (5(b)). When using terms like Environmental Impact Assessment (EIA), Greenhouse Gas Emissions or Ecological Footprint, use consumer-friendly language and explain the meaning or implications.
  3. Evidence (5(c)). All environmental claims shall be supported by "accessible verifiable evidence based on independent studies or third-party certifications".

The Explanation refers to the Guidance Note in Annexure 1. An invented example: a soap maker's label says "eco-friendly". Under 5(a) it must add a qualifier (for instance, what makes it eco-friendly), have substantiation and disclose it as guideline 6 requires.

Guideline 6: adequate disclosures

Sub-guidelineRequirement
6(1)Any person making an environmental claim shall disclose all material information in the advertisement or communication, or by inserting a QR code or URL (or similar digital medium) to disclose detailed material information
6(2)In disclosing, data from research shall not be selected to highlight only favourable observations while obscuring unfavourable ones
6(3)The claim should specify whether it refers to the goods (as a whole or in part), the manufacturing process, packaging, manner of use, disposal, or a service (as a whole or in part) or the process of rendering it
6(4)Comparative claims must be based on verifiable and relevant data and must disclose exactly what aspects are being compared
6(5)Specific claims must be supported by disclosure of credible certification, reliable scientific evidence, internal verifiable evidence, or certificates from statutory or independent third-party verification
6(6)Disclosures shall (i) be easily accessible to the consumer and (ii) not contradict the environmental claim

The claims in 6(5)

Guideline 6(5) lists specific environmental claims that need this kind of support. They include claims that a product is compostable, degradable, recyclable, refillable, renewable or non-toxic; sustainability claims; claims that a product is wholly natural; claims that a product is without a named substance; claims that a product contains no plastic; and plastic-positive, climate-positive and net-zero claims, "and similar claims".

Claim and support at a glance

Claim typeWhat must back it (guideline 6(5))
Compostable, degradable, recyclable, refillable, renewableCredible certification, reliable scientific evidence, internal verifiable evidence, or certificates from statutory or independent third-party verification
Sustainability, climate-positive, net-zeroThe same
A claim that a product is wholly naturalThe same
A claim that a product is without a named substance or contains no plasticThe same
Non-toxicThe same

QR codes and URLs are therefore permitted for detailed disclosures, but the page they lead to must be easily accessible and must not contradict the claim.

Guideline 7: aspirational or futuristic claims

"Aspirational or futuristic environmental claims may be made only when clear and actionable plans have been developed detailing how those objectives will be achieved." A pledge such as "net-zero by a future year" needs a documented plan on how it will be achieved before it is advertised. See the mission statement exclusion in the article on guidelines 1 to 4.

Guidelines 8 to 10

  • Guideline 8: where environmental claims are regulated under any other specific law, rules or regulations, the guidelines are in addition to and not in derogation of that regulation, "except where provisions of the other specific laws being in conflict with these guidelines, the specific law shall prevail".
  • Guideline 9: the decision of the Central Authority is final in case of ambiguity or dispute in interpretation.
  • Guideline 10: the provisions of the Act apply in case of contravention. See the articles on section 21 and sections 88 and 89.

Annexure-I: the guidance note

The guidance note is issued to help industry comply. It has six areas, each with illustrations.

1. Truthfulness and accuracy

Claims must be truthful and accurate, based on verifiable information through certificates by statutory authorities, certificates by credible authorities or internal verifiable evidence.

  • A claim that packaging is made wholly of recycled material, without verifiable evidence or certification, is misleading.
  • "Energy-efficient technology for a greener tomorrow!" without specific data or comparisons "will lack substance".

2. Clarity and unambiguity (guideline 5)

  • "Go green with our product!" is unclear because it does not say what "green" conveys or how the product is environmentally friendly, so adequate qualifiers and substantiation should be provided.
  • "Harnessing the power of sustainable technology!" needs specific details of how the technology is sustainable.
  • "Made with minimal impact on the environment!" without saying what "minimal impact" means downplays or ignores certain environmental concerns.

3. Fair and meaningful comparisons (guideline 6(4))

  • A claim that a cleaning product is without chemicals is vague, since nothing is without chemicals, and misleads consumers by implying that other cleaning products are unsafe.
  • "Our product is greener than the competition!" is misleading without details of which environmental attributes are compared.

4. Claims should be absolute and relevant

Where a claim relates to a specific feature, part or stage, the claim should say so.

  • A plastic package containing a new shower curtain labelled "recyclable": it is not clear whether the package or the curtain is recyclable.
  • A paperboard box in a plastic cover: the box is entirely recycled material, but the plastic cover is not. A claim of recycled packaging would mislead; the accurate claim is "paperboard box: recycled packaging".
  • Hand wash marketed as "biodegradable" without qualification: the advertisement should make clear that only the hand wash, not the bottle, is biodegradable.

5. Use of imagery without substantive claims

Any visual environmental claim that tries to manipulate the consumer into believing a product or service is environmentally responsible, without relevant details or context, is covered. The illustration is a detergent advertisement showing a family playing in an open grass ground with the tagline "Gentle on Clothes, Gentle on Nature", which implies a connection between the product and an eco-conscious lifestyle without directly stating environmental friendliness.

6. Endorsement by environmental organisations, experts or other endorsers

Claims suggesting endorsements, certifications or seals of approval that (i) are non-existent, (ii) are intentionally misleading, or (iii) originate from non-official bodies and lack recognition from credible authorities are misleading and shall not be made.

  • "Recommended by leading environmental experts!" violates the guidelines if there is no backing as described.
  • Labelling a product "certified organic" without proper certification from recognised organic certifying bodies creates a false advertisement.
  • Affixing counterfeit energy efficiency labels on appliances to give the impression they meet standards.

A practical checklist

  1. List every environmental claim and tag it to goods, process, packaging, use or disposal.
  2. Remove generic words or add qualifiers, evidence and disclosure.
  3. Keep certificates or internal verifiable evidence ready.
  4. Disclose material information in the advertisement or by QR code or URL, including unfavourable data.
  5. State exactly what a comparison compares.
  6. Document a plan for each future-looking claim.
  7. Do not use seals or endorsements you cannot prove.

The related advertising conditions are in the article on guideline 4 of the 2022 guidelines.

Need help building an evidence file for environmental claims?

A claim that cannot be backed is a risk. Our compliance advisory team can review your labels and campaigns, identify what evidence each claim needs and help you draft clear disclosures.

Key takeaways

  • Generic environmental words need qualifiers, substantiation and disclosure.
  • Every claim needs accessible, verifiable evidence from independent studies or third-party certifications.
  • Disclosure may be in the advertisement or by QR code or URL; it must be accessible, not contradict the claim and not cherry-pick data.
  • Comparative claims need verifiable data and a clear statement of what is compared.
  • Aspirational claims need clear and actionable plans.
  • The guidance note gives six areas and illustrations, from truthfulness to endorsements.

Read next

Disclaimer: Based on the rules, regulations and guidelines named above as published in the Gazette of India or on the CCPA website, with the amending notifications the article names (consulted on 3 October 2026). Later amendments, the Consumer Protection Act, 2019 provisions referred to, State rules and CCPA advisories should be checked. This article is general information, not legal advice; check the official text before acting.

Quick recapKey facts & short answers

Key Facts About Environmental Claims

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

Can a brand say "eco-friendly"?

Only with adequate, accurate and accessible qualifiers, substantiation and disclosure (guideline 5(a)).

Is a QR code enough for disclosure?

Guideline 6(1) allows a QR code or URL to disclose detailed material information, but the disclosure must be easily accessible and not contradict the claim.

An honest "we were late" filed today is better than a perfect return filed next quarter.

— TaxClue Compliance Desk

Environmental Claims: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

Only with adequate, accurate and accessible qualifiers, substantiation and disclosure (guideline 5(a)).

Guideline 6(1) allows a QR code or URL to disclose detailed material information, but the disclosure must be easily accessible and not contradict the claim.

No. Guideline 6(2) says data shall not be selected to highlight only favourable observations while obscuring unfavourable ones.

Verifiable and relevant data, and disclosure of exactly what aspects are being compared (guideline 6(4)).

Guideline 7 allows aspirational claims only when clear and actionable plans have been developed.

The guidelines apply in addition, but the specific law prevails if it conflicts (guideline 8).