In the wake of the Competition & Markets Authority publishing its landmark Green Claims Code, it’s never been more important for beauty brands to ‘get it right’ on sustainability claims.
So, we got together with Sarah Brown (Pai Skincare), Cecilia Parker Aranha (CMA) and our founder, Jessi Baker, for a live discussion about how beauty brands can meet growing demand from shoppers and regulators for greater transparency about social and environmental impact.
Below, we’ve pulled out 6 key learnings from the session:
1. Brands must comply with the Green Claims Code by the New Year
The CMA’s Green Claims Code comprises 6 principles:
- Claims must be truthful and accurate
- Claims must be clear and unambiguous
- Claims must not omit or hide important relevant information
- Comparisons must be fair and meaningful
- Claims must consider the full life cycle of the product or service
- Claims must be substantiated
But what’s at stake for brands that don’t meet the requirements? As Cecilia Parker Aranha explained: “In the New Year, we’ll be starting to review businesses to look at their compliance with a view to taking enforcement action. If we think a business is doing something that doesn’t comply with consumer law, we can pursue them, ask for commitments that they’ll put things right, and take them to court if they don’t.
2. Marketing an organic product? Get certified
On the subject of communicating about organic ingredients and products, Sarah Brown left no room for ambiguity: “Put your money where your mouth is and get certified.”
She argued that the benefits go beyond having a trust mark on your product, and that it’s an affordable option for small brands: “it's not just about shelling out money; they will really help you through the process. Soil Association, COSMOS, Eco-cert, and USDA, they really will help guide you, and particularly in the more opaque areas, like using endangered plants, which you might not know about. It is actually very affordable, and the fees are structured based on your income and revenues, so it's really fair.”
3. Brands must be specific on recyclability
Brands must give clear instructions on how to recycle their product packaging. Cecilia Parker Aranha called out companies who are failing to do so: “Brands will often not give information beyond ‘recycle’, and they won't tell you how to do that. And that's particularly problematic if you've got a mix of recyclable and non recyclable product and material in the same item.”
Sarah Brown identified regional recycling inconsistencies as a key pain point for brands: “The communication piece is the bit we still struggle on, because we do this great stuff but we really struggle to explain it. The biggest challenge is that we've got no universal kerbside recycling within the UK. So it makes it very difficult.
Nevertheless, she identified the issue as a communications priority for beauty brands: “Packaging recyclability is a key issue for shoppers. Of all of the questions we have around sustainability coming in from our consumers, a lot are around recyclability.
In addition to shopper expectations, Jessi Baker flagged upcoming legislation that means it’s even more important for brands to get ahead on this: “Extended producer responsibility legislation is coming into force in 2023. So even if the Green Claims Code hasn't got you on this, EPR will mandate that all packaging has to be clearly and consistently labelled.”
4. Beauty brands must tell the whole story of their products
What you don’t say about your product matters too. The Green Claims Code specifies that claims must not omit or hide important relevant information. As Cecilia Parker Aranha explained, “what businesses don't say about their products can influence the decisions that consumers make.” She advised brands to share information based on the following rule: “if it's something that consumers would need to know to make an informed decision, then you should be disclosing it.
“From a legal perspective there's no obligation to do a full life life cycle assessment,” she continued, “but make sure that you're not misleading customers by focusing on one narrow element of what you're doing well, while ignoring all of the other things that you're not doing so well.
5. Technology can help brands make substantiated claims
Marketers who’ve read the requirements of the Green Claims Code might well wonder how they’re expected to convey all the information required to support each ‘green’ claim. Cecilia Parker Aranha highlighted the technology solutions available to brands: “One of the things businesses can do if they're making claims or if they want to convey more information to consumers than they have the pack space for is using technology – things like QR codes or or making websites available where customers can go and they can they can read the information that backs up what you're saying.”
However, she shared a crucial caveat for brands looking to use software for their sustainability communications: “It's really important to say for businesses, if you choose to go down [the technology] route, whatever you say to the consumer up front has to be backed up by the information you provide behind the scenes. What would not be acceptable from a consumer protection law perspective would be to make a claim about being carbon neutral but then to have a lot of qualifications hidden away on a website or behind a QR code.
6. Brands can afford to be imperfect, but they must be honest
Sarah Brown’s parting call to action for beauty brands on the line was simple: “Evidence, evidence, evidence. Substantiate what you're saying. Be honest and transparent. I think we've seen time and time again a very forgiving consumer if you're honest. They just want to trust you.”
Cecilia Parker Aranha joined her calls for honesty: “Consumer trust in claims about about the environment is fragile, so it's really really important that businesses are honest are telling the truth and admitting what they're doing well or and not doing well. Otherwise, we risk a complete collapse of trust in products that are trying to meet the demand of consumers. If that happens, it's an existential threat to businesses and it also damages efforts to get consumers to shop more sustainably, and that's just not good for any of us.”
For more great insights from Jessi, Sarah and Cecilia, watch the full webinar below:
Provenance is working with 100+ beauty brands and retailers, using technology to power consistent, credible claims about social and environmental impact. To find out how our Framework and publishing tools can help your business unlock brand value, click here to get in touch.