ICPEN Joint Open Letter to Fashion Retail Sector Worldwide on Use of Environmental Claims

The International Consumer Protection and Enforcement Network (ICPEN) has urged the fashion sector to review its environmental marketing practices to ensure compliance with consumer protection law, and establish that any claims made are truthful, clear and accurate, substantiated with sufficient evidence.

Long Story, Cut Short
  • ICPEN advises those in the business of fashion to ensure that any claims made are truthful, clear and accurate.
  • Giving consumers greater confidence to identify those fashion retailers that they consider to be making the greatest effort to reduce emissions will help to drive innovation and investment in more sustainable technology within the sector.
  • Businesses should consider full life cycle of a product when making claims, including whether there are any negative impacts that would undermine the claim.
The use of vague and general terms in marketing fashion products can mislead consumers into believing that the industry has a lower environmental impact than it actually has, or no negative impact at all. Therefore, claims should be presented in a way that is clear, specific, accurate and unambiguous, both in its factual description and for what is implied.
No lulling to lie The use of vague and general terms in marketing fashion products can mislead consumers into believing that the industry has a lower environmental impact than it actually has, or no negative impact at all. Therefore, claims should be presented in a way that is clear, specific, accurate and unambiguous, both in its factual description and for what is implied. Natalja Danilchenko / Pixabay

A worldwide network of more than 70 consumer protection authorities, under the aegis of the International Consumer Protection and Enforcement Network (ICPEN), has sent an open joint letter to the fashion retail sector encouraging traders to review their commercial practices and ensure that their environmental claims comply with consumer law and sector-specific statutory or regulatory requirements.

  • Focused on consumer protection issues, the letter aims to raise standards in the way that the fashion retail sector makes environmental claims to ensure that consumers are able to make informed choices based on claims that are accurate and clear, relevant in the context of a product or service, and based on reliable and scientifically-based evidence.

Giving consumers greater confidence to identify those fashion retailers that they consider to be making the greatest effort to reduce emissions will help to drive innovation and investment in more sustainable technology within the sector.  National laws may vary, but this letter emphasises that the same basic principles apply to businesses across many different countries. These include:

  • Only make environmental claims when they already have sufficient evidence to substantiate the claim.  
  • Refrain from using product specific claims that are based on evidence that is not specific to the product, for example global average numbers.  
  • Consider the full life cycle of the product when making a claim, including whether there are any negative impacts that would undermine the claim. If the claim does not relate to the full life-cycle, make it clear which part of the life cycle it applies to.  
  • Focus on environmental measures only when significant to the product’s total environmental impact.
  • Refrain from using vague and general claims such as “eco-friendly”, “green” or “sustainable”.  
  • Refrain from using vague and general  terms to describe filters or groups of products in online stores, such as “filter by sustainability” or “sustainable product range”.  
  • Fabrics should be described clearly and precisely, rather than using vague and general terms.  
  • Refrain from using implicit green claims such as images of rainforests, leaf symbols, green backgrounds, etc. that do not give a truthful and accurate representation of the scale of the environmental benefit.  
  • Refrain from using claims as a distinctive feature of the trader while they are based on legal obligations or common practices within the sector.
  • Only use labelling schemes and certifications in line with the criteria of the given labelling or certifications, and explain what components or processes are covered by the scheme, if this is not immediately clear to the consumer
  • Avoid using a trader’s own labelling schemes if they are not widely known and recognised.
  • Refrain from making environmental claims based on certification schemes that go beyond the scope of the certificate.
  • Where relevant, disclose any material connection to a certification, third party scheme or seal of approval  
  • Where a claim requires action by the consumer, and this is not readily apparent, explain clearly what action needs to be taken.
  • Instead of making unsubstantiated claims about future aspirations, focus on the specific measures already taken or currently being undertaken by your company to reach these goals.

THE CONTEXT: The textile industry, including the fashion retail sector, is responsible for an estimated 8% of global greenhouse gas emissions and 20% of global wastewater. Given the sector’s present environmental impact, the potential for introducing meaningful environmental measures is high. 

ABOUT ICPEN: The International Consumer Protection and Enforcement Network (ICPEN) is an organisation composed of consumer protection authorities from over 70 countries, representing some 5 billion global citizen-consumers.

 
 
  • Dated posted: 2 May 2025
  • Last modified: 2 May 2025