Frameworks define what to disclose. Traceability proves what happened.

In Australia the rule is not «don’t lie». It is «have the evidence before you publish»

The ACCC's guidance on environmental claims contains one requirement that reorders the whole process: the evidence has to exist first, and it has to be easy for a consumer to reach. That turns sustainability copy into a documentation problem before it is a writing problem.

Greenwashing, as the regulator defines it

The ACCC's definition is broader than false statements: greenwashing is where a business «uses any claim, or omits key information, that makes a product or service seem better or less harmful for the environment than it really is».

And explicitly: «Omitting information can amount to a false or misleading representation or misleading or deceptive conduct, depending upon the circumstances and the overall impression created.» A business must consider not only its words but «the information that's left out and the visual elements, colours and logos used».

The evidence requirement, and what it actually asks

«Ensure there is clear evidence to back up all claims. Evidence that is independent and scientific is the most credible. The research, evidence, or data a business is relying on should be made easily accessible to consumers.»

Two separate obligations live in that paragraph, and the second is the one that gets missed: hold the evidence, and make it reachable. Evidence in an internal folder satisfies the first and not the second.

For forward-looking statements the bar is stated separately: a business must have «a reasonable basis» for a representation about a future matter, «otherwise, the business should not make such claims at all». A 2030 target is a representation about a future matter.

The three failures the regulator illustrates

Exaggeration by aggregation. A product claims «this product does not harm the environment»; only the bottle is recycled material. A true fact about one component became a claim about the whole.

Omission that reverses the meaning. An airline advertises «reducing emissions» while sustainable fuel covers under 1% of its schedule and total emissions are forecast to rise. Each sentence survives; the impression does not.

A condition left unsaid. Cups advertised as «recyclable» are only recyclable through in-store bins, and contaminate other streams anywhere else.

The words the regulator tells businesses to stop using

The ACCC names «green», «environmentally friendly» or «eco friendly», and «sustainable» as overly broad, and recommends avoiding them: the first «conveys little information», the second risks implying no harm when «few, if any, products can truthfully make this claim», and the third is «overly general».

That list is worth reading as a procurement filter as much as a copywriting one.

Writing a claim that survives: write the evidence first and the sentence second; publish the source next to the claim; quantify and bound it; state the conditions in the same breath as the benefit; and treat targets as regulated speech.

A supplier whose sustainability page runs on those three words has told you nothing the regulator considers informative.
Write the evidence first and the sentence second. If the sentence exists and the evidence is pending, there is no claim yet.
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