Review a Canadian environmental claim before it reaches the public

Before publishing an environmental claim in Canada, freeze the exact words, images and placement, then test the evidence against both the literal statement and the overall impression a reader may receive. Approve, revise or hold the claim as a specific record.

The Competition Bureau's current page contains an important update: on 26 March 2026, Budget 2025 Implementation Act, No. 1 received Royal Assent and removed the requirement for environmental claims to be supported by an internationally recognised methodology. The Bureau says it will update its guidance. Teams should therefore not rely on older passages that still repeat the removed methodology wording. Competition Bureau environmental claims guidance

The remaining rules against materially false or misleading public representations, including the general impression, still require careful evidence and legal assessment. This guide is an operational review method, not legal advice.

Review the complete advertisement, not a slogan in isolation. Identify whether the claim concerns a product, performance, business or future result. Match the boundary and time period of the evidence to the words used. Recheck claims when evidence, products or official guidance changes.

Capture the exact wording, image, footnote, link, audience, channel and publication date. A qualifying statement hidden behind another click may not correct the main impression. Record translations and shortened social versions separately.

Identify the subject: one product, a product line, one facility, a service, or the whole business. Words such as “green,” “clean,” “carbon neutral” or “renewable” can imply a broader benefit than the evidence actually addresses.

Record who requested the claim and who can approve it. Keep marketing ownership distinct from technical evidence ownership and legal review. Do not let a campaign deadline convert an unresolved assumption into approval.

Use fields for the exact claim; subject and boundary; comparison or baseline; reporting period; evidence source and version; method or test; exclusions; uncertainty; responsible owner; approval; and expiry or review date.

For a product performance or environmental benefit claim, verify whether adequate and proper testing is required and whether testing existed before the claim. For a business or future claim, preserve the current facts, plan, milestones and governance needed for substantiation. The Bureau's high-level principles still stress truthfulness, proper testing where applicable, specific comparisons, no exaggeration, clear wording and substantiated future claims.

Test the general impression using someone who was not involved in drafting. Ask what the claim appears to promise, which product or business it covers and what timeframe it suggests. Record the answer; do not coach the reviewer toward the intended meaning.

Assume a fictional Canadian company proposes: “Our operations used 100% renewable electricity in 2025.” Its evidence covers nine months, one facility and a contract instrument, while two other sites are missing.

The review holds the claim. The business may gather the missing evidence or narrow the statement to the supported facility, period and basis, with a clear explanation. It must also confirm the accounting treatment and current legal review before release. The GHG Protocol Scope 2 Guidance can inform corporate electricity accounting, but it does not approve Canadian marketing wording.

This example is hypothetical. It is not a conclusion about renewable-energy instruments, a real advertiser or legal compliance.

For the fictional three-site company above, the reviewer can close the first review without pretending the evidence is complete:

Do not convert one of three sites into “33% renewable”, or nine months into “75% renewable”. Site counts and elapsed months are not electricity quantities, and they say nothing about the missing sites' consumption or the instrument's validity. A numerical share would require a supported electricity denominator and a supported numerator on the same boundary.

The evidence owner obtains the missing records; marketing keeps the claim out of the release queue; the reviewer records which revised wording was actually assessed. Any narrower statement must still describe its basis clearly and pass the applicable technical and legal checks.

This is a proposed record for an invented campaign, not evidence of a conducted review. Store the final claim text with the exact evidence assessed so a later campaign cannot inherit approval automatically.

Give every time-sensitive claim an expiry or review trigger. Supplier data, emissions factors, product design and official guidance can change. Assign someone to pause or amend live content when the evidence no longer supports the statement.

Keep a record of revisions and withdrawal. If a claim is corrected, identify every channel where it appeared. Do not update the website while leaving the same unsupported words in sales material or marketplace listings.

Because the Bureau says its guidance will be updated after the March 2026 amendment, recheck the official page immediately before publication and before reusing the claim.

Global campaigns should share evidence fields and version control, but legal assessment must remain market-specific. The UK guide on green claims evidence for retail supply chains offers a useful supplier-evidence discipline; it does not determine Canadian law.

Record which version is approved for each market. Prevent content systems from automatically copying one country's claim into another channel without the required review.

No. The official Bureau page says the internationally recognised methodology requirement was removed. Other deceptive-marketing provisions and evidence requirements remain relevant, and the page is awaiting an update.

Not necessarily. The overall context, words, images and layout contribute to the general impression. A disclaimer cannot be assumed to cure a broad or misleading main claim.

It may be part of the evidence, but verify its subject, period, method, independence and limits. The advertiser should understand why the evidence supports the exact public wording.

This article is general information. Verify current requirements and seek qualified advice for your specific circumstances.

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