The Australian Competition and Consumer Commission today published guidance telling businesses that marketing which blends purchased carbon credits with real emissions reductions is likely to mislead consumers, setting out one "Golden Rule" and six prompts that will shape how it assesses climate claims in packaging, websites, television and outdoor advertising.

In Short

Australia's consumer watchdog wrote a rulebook for companies that boast in ads about cutting their greenhouse gas emissions. If a company says it cut its pollution in half but really just bought credits from a forest project somewhere else, the watchdog thinks most shoppers would be fooled. From now on, any company making these claims will be judged on what an ordinary person takes away from the ad, not on the fine print or the technical accounting behind it.

What the ACCC published

The document is titled "Making emissions claims to consumers - a guide for business." It runs to 24 numbered pages, carries the reference ACCC 10/26_26-67 and is dated October 2026. The accompanying media release, number 119/26, is dated 20 October 2026.

According to the release, Australian businesses making greenhouse gas emissions claims "should use credible, science-based accounting standards, be transparent about the use of purchased credits, and, above all else, consider what average consumers would understand their claims to mean." The release frames the guide as a tool for businesses that want to promote climate action and need to understand "potentially problematic behaviour and risks in failing to consider the consumer perspective when advertising emissions data."

The legal hook is the Australian Consumer Law, which prohibits false or misleading representations and misleading or deceptive conduct. The ACCC states plainly in the guide that it "is not an environmental regulator." Its role is consumer protection, and the guide reads accordingly: almost every example turns on the gap between what a company's accounts show and what a shopper would believe after seeing a billboard, a swing tag or a social media post.

ACCC Deputy Chair Mick Keogh put the commercial case in two parts. "Consumers should be able to trust the emissions-related claims that businesses make," he said, according to the release. "Greenwashing not only limits the ability of consumers to make informed purchasing decisions, but it also disadvantages businesses that have invested in the development of products or services that are genuinely more environmentally sustainable."

He also acknowledged that the underlying discipline is difficult. "We recognise that greenhouse gas emissions accounting is complex and increasingly regulated. Our guidance is particularly aimed at helping businesses to understand their consumer law obligations when making voluntary marketing claims to consumers," Keogh said. His closing instruction was direct: "If any existing claims raise concerns, businesses should update their messaging, gather stronger evidence, or reconsider using it."

Scope: marketing, not mandatory reporting

The guide covers "product packaging, point of sale promotions, advertising and general website content." It explicitly does not apply to "specifically regulated contexts such as mandatory climate reporting or mandatory labelling." There is a catch, however. Where statements from those regulated contexts are reproduced in consumer-facing claims, according to the ACCC, consumer law applies and businesses are encouraged to consider the guidance.

That carve-back matters for any company that lifts a figure from its sustainability report and drops it into a television spot. Several of the guide's worked examples involve exactly that move, and in each one the ACCC concludes that a technically accurate reported number produced a misleading advertisement.

The guide also builds on, rather than replaces, the ACCC's 2023 publication "Making environmental claims - a guide for businesses," which set out eight principles for trustworthy environmental claims. The new document applies those principles to emissions specifically. On enforcement, it points back to page 34 of the 2023 guide, noting that the regulator will consider whether a business "made genuine efforts and took appropriate steps to verify the accuracy of any information relied on." Smaller businesses get some room: the ACCC says it recognises they "may not have access to the same resources as larger businesses," and that this will be taken into account.

Why publish guidance at all, rather than wait for judgments? The ACCC gives its own answer: "there are limited cases where Australian courts have judged these issues."

The Golden Rule: the dominant message wins

Everything in the guide hangs on what the ACCC calls the Golden Rule: consider the consumer audience, because marketing context matters. The test is the "dominant message, or the overall impression" a claim creates for "an ordinary and reasonable consumer."

Three consequences follow, each with obvious implications for creative and media teams.

First, images count as claims. "Images, colours and icons matter," the guide states. A forest backdrop or a smiling planet can make a business "seem greener than it really is." Two of the worked examples, a hybrid SUV filmed driving through forests and an energy retailer's billboards featuring a smiling Earth, are judged likely to mislead in part because of the imagery.

Second, fine print does not rescue a headline. "Small print, asterisked links, or disclaimers are unlikely to be enough to change the dominant message of a prominent headline claim," according to the guide.

Third, the channel changes what is acceptable. Consumers viewing "a billboard, TV or radio ad may only take in a short, simple message," the guide says, so "complex, technical language and nuanced terms should be avoided." A website, by contrast, "can allow for more detailed explanations." The guide repeatedly suggests moving nuanced material - transition plans, accounting boundaries, credit registries - to web pages or QR codes, while keeping short-form copy to specific, already-achieved facts.

The audience question gets similar treatment. Language suitable for regulators or institutional investors "may be misleading when used in short-form advertisements to a broad cohort of consumers." The ACCC singles out "net zero" as a term that "has a particular meaning in a regulatory or technical context" but may be understood differently by shoppers.

Six prompts, one checklist

Beneath the Golden Rule sit six prompts, summarised in a one-page checklist. Each row poses a question and states what to do if the answer is "no or not sure." The simple rule at the bottom of that table echoes Keogh's quote: "If any check raises concerns, refine your messaging, gather stronger evidence or reconsider using it."

Prompt 1: complete, reputable and clear accounting

Calculations behind a claim must, according to the guide, substantiate the dominant message, show how a figure was reached, use "established, reputable emissions accounting frameworks," compare against realistic baselines "not picked to over or underestimate the true position," include all significant emission sources, explain and justify any omissions, and be understandable "by a person without technical knowledge."

The guide lists five tests for an accounting framework: relevance, completeness, consistency, transparency and accuracy. It also warns that third-party certifications and trust marks do not shift responsibility. Reliance on them "does not change your businesses' responsibility to make sure its claims are not misleading or deceptive."

The worked example is pointed for the digital industry. A social networking business reports a 43% cut in scope 1 and 2 emissions for its Australian arm, driven by renewable energy purchases and a switch from gas to electric heating. It runs a website and television campaign saying "We have reduced our emissions by 43%," with an asterisk referencing its 2025 corporate reporting obligations. The problem is an offshore data centre the company does not own, which is "essential to delivering the social networking services to Australian users." Those emissions would be scope 3, which the company does not yet report. Counting them, the total reduction is 10%.

The ACCC's conclusion: the reasonable consumer "is likely to assume that the business has reduced its overall emissions by 43%," and the asterisk "is not enough to change the dominant message." The suggested compliant version says 10%.

For a sector whose services run on third-party cloud infrastructure, the example is hard to miss. The guide defines scope 3 as emissions "that occur in the value chain of an entity, but which are outside of the business's operational control," citing definitions adapted from ASIC, the Clean Energy Regulator and the Greenhouse Gas Protocol.

Prompt 2: no highly selective or broad claims

The guide names a list of terms that "may create the misleading impression that your business's contribution to combating climate change is more than it currently is" when used in short-form marketing: "clean," "sustainable," "carbon neutral," "climate neutral," "climate positive," "climate friendly," "carbon positive" and "net zero." The risk is highest, according to the ACCC, "when the claim is used to influence consumer purchasing decisions and used in isolation and on product-level marketing."

Words such as "net," "neutral" and "positive" are flagged as ambiguous because consumers may read them as absolute quantities when they are used in a relative sense. Comparisons face the same scrutiny. A phrase like "lower emissions" needs context about what is being compared and why. Emissions-intensive businesses, including those that "rely on or sell fossil fuels or manage waste," are told to take particular care not to present a reduction in one part of the business as a significant reduction for the whole.

Four examples illustrate the point. An online retailer outsources its delivery fleet, reports a 90% drop in scope 1 emissions against 2020, and advertises the figure, even though its overall impact is unchanged because the emissions moved into scope 3. A jeans maker labels its products "Climate Positive" on the basis of plant-based fabric while ignoring manufacturing and transport. A carmaker promotes hybrid SUVs as "planet friendly" despite holding real-world data showing tailpipe emissions "equivalent to or higher than, many comparable petrol SUVs." All three are judged risky.

Two examples are presented as acceptable. An electric vehicle advertisement claiming zero tailpipe emissions "compared with 2.8 T," footnoted to a 15,000 km real-world comparison, "is not likely to mislead consumers because it clearly identifies the basis for the comparison." A small café's window poster describing rooftop solar, a battery and electric grills is labelled "low risk."

Prompt 3: transparency about credits

This is the prompt with the widest reach, and the one the release emphasises. Businesses can reduce emissions directly or buy "carbon credits, units or tradeable certificates" from projects elsewhere. The guide treats the word "offset" itself as a hazard: it is "the type of technical language which, in isolation, may mislead or confuse consumers" because it can convey "that 2 activities are equivalent, when this may not be the case."

The ACCC's reading of consumer understanding is specific. "Most consumers may interpret a statement like 'We've reduced our emissions' or 'We're reducing our net emissions' to mean that the business itself has taken direct steps to reduce the emissions its operations create," according to the guide. They "would not think that the business has purchased and surrendered credits from someone else to change their emissions account on paper."

On equivalence, the line is drawn by project type. A claim that credits "counterbalance" ongoing emissions may be reasonable if the credits come from projects "which permanently sequester and store carbon, as verified by a reputable crediting scheme." A claim to have "neutralised" a product's emissions "may mislead consumers if the claim is based on the purchase of credits from projects which 'avoided' emissions from a hypothetical source a number of years ago."

The good-practice list asks businesses to say the claim relies on purchased and surrendered credits, describe the project and when it occurred, name the scheme and the registry, and verify integrity against three principles: additionality (the benefit would not have happened without the project), permanence (stored carbon stays sequestered for a period consistent with the claim) and no double counting. Co-benefits advertised from projects must be real, and the guide names "modern slavery issues in the supply chain" among the risks to check.

Two examples show the consequences. A brick maker buys reforestation credits equal to 50% of its annual emissions, changes nothing in its factories, and advertises "We have reduced our emissions by 50%." The ACCC calls this "likely to be misleading." An energy retailer called EnerG0 buys avoided-emissions credits matching its customers' consumption and runs capital-city billboards reading "Zero Impact Energy." Because the credits "do not lead to the permanent removal of greenhouse gases from the atmosphere," the guide says they "do not provide a reasonable basis" for the claim.

The suggested replacement text for EnerG0 is notable for what it concedes to the customer: "This won't reduce or cancel out the emissions from your home's energy use, but it will support projects that can help to avoid emissions elsewhere." (The guide's suggested billboard line for the same example, "Choose EnerG0's we support Australian energy efficiency projects, find out how," appears garbled in the published PDF.)

Prompt 4: no double counting

The fourth prompt targets a familiar accounting trick. According to the ACCC, on-site solar cannot support a claim of reduced scope 2 emissions if the same business also generates and sells renewable energy certificates for that electricity, because the buyer of those certificates can then claim the same benefit. Credits and the activities behind them "should not be counted as part of an emissions inventory or product footprint" unless the certificates have been surrendered on the relevant registry on behalf of the entity claiming them.

The examples include a cattle farm marketing "Climate neutral beef" while a separate carbon project manager sells certificates from revegetation on leased farmland to third parties, and a snack maker advertising chips "made with renewable energy" while generating certificates from its own solar panels. In both cases the ACCC lists the information it would be "likely to request," from full life-cycle emissions to the surrender history of every certificate.

The good-practice counterpart describes a breakfast cereal maker that combines on-site solar with a bundled power purchase agreement with a wind farm in the same state and surrenders both sets of certificates annually.

Prompt 5: own action versus the grid and the law

"You should not claim to be responsible for emissions reductions unless your business has taken specific action to achieve this outcome," the guide states. Grid-wide gains are the clearest example. A building materials company that has made no renewable investment advertises that its manufacturing "is now powered by 35% renewable electricity." In that year, 35% of Australia's total electricity generation came from renewables. The ACCC judges the claim likely to give "the misleading impression that Build Co has taken proactive steps."

Legal obligations get the same treatment. Where a reduction is required by regulation, the guide warns against leaving consumers with the impression that it was voluntary. A sandstone quarry that is "30% below our legal emissions baseline" as of 2026, achieved "through process improvement and fleet electrification" with "no credits," is offered as good practice because it separates compliance from over-delivery.

Prompt 6: reasonable grounds for future claims

The final prompt deals with targets. Businesses "should not feel consumer law prevents them" from communicating plans, according to the guide, but they must separate what is happening now from what is planned, and disclose dependencies on technology, regulation or government support. Aspirational targets "may be appropriate to discuss in corporate communications such as annual reports or sustainability reports," but the caveats they need make them "often not suitable for product branding or short-form advertising."

The guide's running example is a freight company advertising "Planet friendly delivery - Net zero emissions by 2050." When the ACCC revisits it under this prompt, the company's board has passed a resolution adopting the target. That, the guide says, is not enough: "Merely passing a resolution of the board accepting a target without having a reasonable basis for how you will reach the target would be insufficient to substantiate this consumer-facing claim." The ACCC lists what it would request: emissions accounts and baselines, committed expenditure, cost projections, interim milestones and governance processes.

One detail in the revisited example differs from its first appearance. The opening version describes an outdoor advertising campaign; the revisited version places the same tagline on a banner on the company's booking website, and renders "guilt free" as "guilt fee." The analysis is the same in both.

Enforcement record behind the guidance

The release ties the guide to an enforcement programme that has been running for three years. Greenwashing became an ACCC compliance and enforcement priority in 2023, the same year the general environmental claims guidance appeared, and the release says consumer and fair-trading concerns about environmental claims remain "a current ACCC compliance and enforcement priority."

According to the release, the ACCC has since observed "significant changes in some of the sustainability claims of large companies across sectors such as aviation, energy, logistics and telecommunications." Some companies have moved away from "vague, widely advertised, carbon neutral claims, distant future targets and limited transparency about their reliance on credits." The regulator calls this a "positive trend" and says it will "consider targeted enforcement action for on-going problematic conduct where it is appropriate."

The release cites three cases. The Federal Court ordered Clorox Australia to pay A$8.25 million in penalties for misleading "ocean plastic" claims on certain GLAD products. The ACCC has started Federal Court proceedings against Australian Gas Networks over its renewable gas campaign, and against the maker of Banana Boat and Hawaiian Tropic sunscreens over "reef friendly" claims. The release also notes that ASIC separately enforces misleading statement prohibitions for sustainability-related financial products such as managed funds.

That record sits alongside a run of ACCC advertising cases that PPC Land has followed through 2026. The regulator obtained A$15 million in penalties against Emma Sleep in April over fake countdown timers and strikethrough prices on 74 products. In June, Hismile paid A$138,600 after staff appeared as random members of the public in social videos. The ACCC sued Amazon over ads introduced to Prime Video for more than 850,000 annual subscribers who had already paid, and in July the Federal Court fined JustAnswer A$10 million over a A$2 joining fee that enrolled users into subscriptions of A$45 to A$75 a month. In September, digiDirect paid A$99,000 after a Black Friday sweep.

The ACCC's 2026-27 priorities, set out in February, emphasised manipulative online practices, supermarket and essential-service pricing and motor vehicle guarantees. The emissions guide makes clear that environmental claims remain an active line of work alongside them.

Why this matters for marketers

The guide is written for any business, but several of its examples describe situations that the advertising and technology sector knows well.

The social network example is effectively a warning about cloud and data centre emissions sitting outside a company's reported boundary. That boundary question has become sharper as AI infrastructure grows. PPC Land reported in July 2025 that Meta's planned AI data centres would consume energy equivalent to four to five million American homes, and on 19 October covered Amazon's backing of a 960MW nuclear project in Indiana, described in the context of the company's goal of net-zero carbon by 2040. Claims about "renewable-powered" services built on such infrastructure now have a detailed Australian benchmark.

Energy certificates are the second overlap. PPC Land's explainer on power purchase agreements notes that each megawatt-hour of renewable generation creates an energy attribute certificate that feeds scope 2 reporting, and that "powered by renewable energy" is advertising copy subject to green-claims rules. The ACCC's double-counting prompt and its Build Co grid example spell out how Australian consumer law treats that copy.

The ad tech industry's own sustainability marketing is the third. Vendors have promoted emissions reductions from supply path optimisation and creative compression; at an IAB Europe webinar covered by PPC Land, ad tech firms presented carbon reduction results including a 38% cut in bidstream emissions and 44 tons of CO2e avoided across campaigns. Those were business-facing claims, and the guide is aimed at consumer marketing. But brands that pass such figures through to consumer campaigns - "our ads are greener" - would fall under its reasoning on selective claims and complete accounting.

Then there is the creative itself. The guide's position that imagery, colour and icons carry meaning, and that disclaimers rarely correct a headline, applies directly to how emissions claims are produced and placed. A single message can be acceptable on a landing page with room for qualification and risky on a six-second video or a billboard. Media planners and creative teams working on Australian campaigns now have a regulator's document stating that distinction in writing.

PPC Land has also tracked the parallel concept of "AI washing," which academic research compared directly to greenwashing in December 2025, and the ACCC itself flagged AI washing as a form of misleading conduct in a December 2025 report on AI developments. The emissions guide follows the same pattern: a regulator taking a claim category where buyers cannot verify the product themselves, and writing down what substantiation it expects to see.

What the guide does not do

The guidance has no legal force of its own. "Ultimately, whether conduct or representations made by businesses breach consumer law is a matter for the courts to determine," the guide states, and its important notice says it "does not constitute legal or other professional advice." It sets no thresholds, prescribes no single accounting standard and introduces no new penalties.

The release's opening sentence calls for "science-based accounting standards"; the guide itself uses the broader phrase "established, reputable emissions accounting frameworks" and leaves the choice to businesses, provided they apply it consistently. Treasury's voluntary Climate-Related Transition Planning Guidance is referenced for companies building transition plans.

What the document does provide is a list of the questions the ACCC says it is "likely to request" answers to when it examines a claim. For a business weighing whether a "carbon neutral" badge or a percentage reduction belongs in a campaign, that list is the closest available indication of what an investigation would look for.

Timeline

Summary

Who: The Australian Competition and Consumer Commission, with Deputy Chair Mick Keogh as spokesperson, addressing every Australian business that makes greenhouse gas emissions claims to consumers.

What: A 24-page guide, "Making emissions claims to consumers - a guide for business," built on a Golden Rule about the ordinary consumer's overall impression and six prompts covering accounting, specificity, carbon credits, double counting, own action versus legal or grid-wide change, and future targets. Its central position is that marketing which presents purchased credits as emission reductions, or treats avoided-emissions credits as neutralising ongoing emissions, is likely to mislead.

When: Today, 20 October 2026, in media release 119/26, three years after greenwashing became an ACCC priority and the 2023 environmental claims guide was published.

Where: Australia, under the Australian Consumer Law, applying to packaging, point of sale, advertising and website content, but not to mandatory climate reporting or labelling unless that material is reused in consumer marketing.

Why: According to the ACCC, consumers cannot verify emissions claims themselves, misleading claims disadvantage businesses with genuinely lower-emission products, and there are few Australian court decisions on the subject. The regulator says it will consider targeted enforcement against ongoing problematic conduct.