Sustainability has never been more central to how clients choose their promotional products partners. But as green claims have become a competitive differentiator, so has the risk of greenwashing — and in Australia and New Zealand, that risk now carries very real consequences.
Greenwashing is making environmental or sustainability claims that are false, misleading, or cannot be substantiated. It doesn't have to be intentional to be a problem. Using terms like eco-friendly, sustainable, carbon-neutral, or 100% recycled without the evidence to back them up puts your business — and your clients — at legal risk under the Australian Consumer Law.
The ACCC has made environmental claims a sustained enforcement priority. In a sweep of 247 Australian businesses, 57% were found to be making claims with the potential to mislead consumers. In December 2023, the ACCC published its definitive guidance on making environmental claims — eight principles every business making green claims should know. From March 2025, the AANA's new Environmental Claims Code raises the bar further still.
ACCC — Environmental and sustainability claims guidance
ACCC Greenwashing Guidelines (PDF)
These apply directly to any green claims you make in your nomination submission:
Third-party certifications are one of the strongest tools available to distributors making sustainability claims — but only when used correctly. The ACCC is explicit: certifications must be ones you can explain, and they must actually substantiate the specific claim being made. A business-level certification doesn't automatically validate every individual product claim.
Three frameworks that regularly come up in the APPA community are worth understanding clearly:
B Corp is a whole-of-business certification awarded by B Lab to companies that meet high standards of social and environmental performance, accountability and transparency. It assesses governance, workers, community, environment and customers. For distributors, holding B Corp status signals genuine organisational commitment to sustainability — and it's increasingly recognised by clients as a credible marker of purpose-driven business.
However, B Corp is a company-level certification, not a product-level one. It doesn't automatically validate claims about a specific product being "eco-friendly" or "sustainable." If you're B Corp certified and nominating for the APPA award, reference it as evidence of your business's broader sustainability commitment — but pair it with specific, substantiated claims about the campaign or initiative itself.
EcoVadis is a globally recognised supply chain sustainability rating platform that scores companies across four pillars: environment, labour and human rights, ethics, and sustainable procurement. It's increasingly becoming the standard assessment tool in the promotional products industry globally, with companies awarded bronze, silver, gold or platinum medals based on their overall score.
EcoVadis is particularly strong for demonstrating supply chain due diligence — a critical area when making claims about how and where products are made. If your suppliers hold an EcoVadis rating, or if your own business has been assessed, this is meaningful, documentable evidence that can credibly underpin sustainability claims in a nomination. Note that EcoVadis assessments are based largely on self-reported documentation, so having supporting audits or certifications alongside it strengthens its weight further.
APCO is the peak body leading the development of a circular economy for packaging in Australia. It administers the Australian Packaging Covenant — a co-regulatory framework under national environment protection legislation — and works with businesses across the packaging supply chain to reduce environmental impact.
APCO membership and compliance is most directly relevant when your nomination involves claims about packaging: recyclable materials, recycled content, reduced packaging waste, or design for end-of-life. If your initiative involved packaging decisions aligned with APCO's national targets (such as using packaging that is reusable, recyclable or compostable), membership or compliance with the Covenant is useful supporting evidence — and importantly, it's government-backed, which carries weight with judges assessing substantiation.
Whichever certifications or frameworks apply to your work, the ACCC's principle is consistent: only reference certifications in a way that accurately represents what they certify. Don't let a business-level credential carry claims that need product-level evidence. Use certifications to support your case — not to replace it.
These aren't hypothetical risks. The ACCC has moved from issuing guidance to active enforcement, and the penalties are significant.
| Case | What happened |
|---|---|
| Clorox — April 2025 $8.25 million fine |
Fined for claiming its kitchen and garbage bags were made from "50% Ocean Plastic". The wave imagery and blue packaging created a false impression about where the plastic was sourced. |
| Major supermarket — September 2024 Complaint upheld |
Ad Standards upheld a complaint about an in-store freezer sticker claiming the business was "Powered by 100% renewable electricity." Even with supporting evidence, the claim as displayed was found to be misleading. |
| MOO Premium Foods — November 2023 Court undertaking |
The ACCC accepted a court-enforceable undertaking after the company claimed its packaging was "100% ocean plastic." The resin was collected from coastal areas — but not directly from the ocean. Close enough wasn't good enough. |
The APPA Sustainable/Eco-Friendly Initiative Award requires all entries to comply with ACCC (or Commerce Commission NZ) guidelines and to be able to substantiate every claim in the submission. This is a judged requirement, not a formality.
A nomination built on vague or overreaching sustainability language won't just struggle with the judges — it could expose your business to scrutiny it didn't anticipate.
The APPA Sustainable/Eco-Friendly Initiative Award exists to celebrate real progress — campaigns and initiatives that genuinely moved the needle for clients and the environment. If your work is the real thing, the nomination should be too. Specificity and honesty aren't just good practice; they're what separate a winning entry from a risky one.
