Last updated 28 September 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. References are to the Consumer Protection (Fair Trading) Act 2003 as in force on 28 September 2026, the CCS Guide on Quality-related Claims published on 6 October 2025, and the Singapore Code of Advertising Practice. For a specific claim, take advice from a lawyer or the Competition and Consumer Commission of Singapore.
“Eco-friendly”. “Sustainable”. “Made with recycled materials”. “A greener choice”. These are some of the most common words in Singapore product marketing, and they are also the words most likely to get a brand into trouble. When researchers looked at more than a thousand products sold on the e-commerce sites Singaporeans visit most, 51% carried environmental claims that were vague or unsubstantiated.
The regulator has since moved. On 6 October 2025 the Competition and Consumer Commission of Singapore, which now brands itself CCS, published its Guide on Quality-related Claims. It grew directly out of concerns about greenwashing, and it sets five principles that every environmental claim in an ad, product listing, package or social post should pass.
This guide explains what those principles mean for marketing copy, what law sits behind them, where the self-regulatory advertising code adds stricter rules, and how to rewrite the most common green claims so they still sell without misleading anyone.
What law actually applies to green claims in Singapore
There is no dedicated greenwashing statute in Singapore. Environmental claims are governed by the same general law that covers every other claim about a product, plus a self-regulatory code on top.
| Layer | What it is | What it does to a green claim |
|---|---|---|
| Consumer Protection (Fair Trading) Act 2003 (CPFTA) | Statute, enforced by CCS and by consumers themselves | A misleading or false green claim in a consumer transaction is an “unfair practice” |
| CCS Guide on Quality-related Claims (Oct 2025) | Regulatory guidance, not binding law | Explains how CCS reads the CPFTA for quality and environmental claims; five principles |
| Singapore Code of Advertising Practice, Appendix L | Self-regulatory code administered by ASAS | Specific rules on “environmentally friendly”, “biodegradable” and comparative green claims |
| Trade Descriptions Act 1975 | Criminal statute on descriptions of goods | False statements of composition, such as “100% recycled plastic”, can also be false trade descriptions |
How a green claim becomes an unfair practice
Section 4 of the CPFTA makes it an unfair practice for a supplier, in relation to a consumer transaction, to do or say anything, or omit anything, such that a consumer “might reasonably be deceived or misled”, or to make a false claim. It also captures anything listed in the Act’s Second Schedule. Several items in that Schedule read almost as if they were written for greenwashing:
- Para 1: representing that goods have sponsorship, approval, performance characteristics, ingredients, components, qualities, uses or benefits that they do not have. “Plastic-free packaging” on a pouch lined with plastic film is a component claim.
- Para 2: representing that the supplier has a sponsorship, approval or affiliation it does not have. A certification logo you are not licensed to use falls here.
- Para 4: representing that goods are of a particular standard, quality, grade or method of manufacture when they are not.
- Para 23: omitting a material fact, or using small print to conceal one. The footnote that says the “recycled” claim applies only to the cap is the classic case.
The consequences run on two tracks. Consumers can sue under section 6 for claims up to $30,000, usually through the Small Claims Tribunals. CCS can apply to court under section 9 for a declaration or an injunction, and the court can add orders requiring the business to publicise the order or notify affected consumers. Section 10 extends injunctions to anyone who knowingly abets, aids or procures the unfair practice, which is the provision that can reach an agency that knowingly writes misleading copy. Breach of an injunction is contempt of court.
One point that is often misreported: as at September 2026, CCS has no power to impose administrative fines for unfair practices. Its route is the courts. The practical sting is the injunction, the public naming that comes with it, and the cost of pulling and reprinting packaging.
What the 2023 greenwashing study found
The Guide did not come out of nowhere. In March 2022 CCCS funded the NUS Business School Centre for Governance and Sustainability to study green claims online. The team examined more than 1,000 products on the 100 most-visited e-commerce websites for Singapore residents in October 2022, and published its findings on 16 November 2023.
Three findings matter for marketers. First, the problem is mostly vagueness, not outright lies: words like “environmentally friendly”, “eco-friendly”, “green”, “sustainable”, “natural”, “conscious” and “responsible” used with nothing to explain what they mean. Second, technical jargon was a real issue in furniture and appliances (24%) and marketplaces (17%), where invented or unexplained terms signalled a benefit nobody could check. Third, the rate was highest where many small sellers write their own listings. If you sell on Shopee, Lazada or Amazon, your listing copy is the exposure.
The five principles in the CCS Guide
The Guide covers all “quality-related claims”, not only environmental ones, but most of its worked examples are green. It applies to claims made through “words, images, symbols, brand names, certifications, certification stamps or logos”, in print, online, on social media and on packaging. The test is the overall impression a reasonable consumer would form. CCS says it will focus on egregious cases and will consider whether a business made genuine efforts to verify its claims, as well as its size and resources.
The five principles, using the Guide’s own headings:
1. Claims should be true and accurate
The basic rule, with two extensions that catch marketers out. First, a business should verify information from its suppliers before repeating it. The Guide’s example is a retailer’s “Choose Green” section that simply reproduces manufacturers’ claims without checking them. “The supplier said so” is not a defence. Second, a business should not market an ambition or goal it cannot reasonably achieve or does not intend to meet. Claims should also be reviewed periodically, because a claim that was true at launch can become false when a formulation or supplier changes.
2. Claims should be clear and easily understood
Vague and broad claims are more likely to mislead. The Guide warns against using terms, symbols or imagery out of their common context, against self-declared labels that look like independent verification, and against made-up technical terms. Its example is a washing machine sold with “environmentally sustainable Eco-soft Technology” that used less water but more harmful chemicals. A home-made green leaf badge reading “Certified Eco” is exactly what this principle is aimed at.
3. Claims should be meaningful
Do not trumpet an attribute that is mandatory, standard across the category, or insignificant. The Guide’s example is a hair spray marketed as better for the environment because it is CFC-free, when CFC aerosols have been banned since 1991. Comparisons must be like for like, and you should be ready to say what you compared against. A salad sold as “a greener choice with 27% less packaging” fails if the reader cannot tell 27% less than what.
4. Claims should be accompanied by material information
State the limits, conditions and assumptions behind a claim. Name the certification body and what its scheme certifies, and prefer reputable third-party schemes. Where you claim a benefit or outcome, say what actions produce it and whether it only arrives over the longer term. The qualifying information must be clear and prominent. Where space is tight, the Guide accepts a URL or QR code leading to the detail, but it expressly links hiding a material fact in small print to the CPFTA’s para 23.
5. Claims should be supportable by evidence
Hold current, valid and credible evidence before you make the claim, such as test results, certifications or peer-reviewed research. Do not rely on unrepresentative or inconclusive studies, or imply scientific consensus where none exists. Certification claims need evidence of ongoing compliance; displaying an expired certification logo is one of the Guide’s examples. Ambitions and targets need “credible and corroborative evidence” of intent and of the steps being taken, and projections should use internationally recognised assessment and accounting methodologies.
Where the advertising code is stricter
The Singapore Code of Advertising Practice, administered by the Advertising Standards Authority of Singapore (ASAS), has a dedicated Appendix L on environmental claims. It is self-regulatory, so breaching it is not an offence, but ASAS can ask media owners to stop running an ad, and platforms and publishers in Singapore generally comply. Appendix L goes further than the CCS Guide in places:
- L1: the basis of any environmental claim should be explained and qualified where needed. Unqualified claims can mislead by omission.
- L2: absolute terms such as “environmentally friendly” or “wholly biodegradable” should not be used without qualification unless there is convincing evidence that the product will cause no environmental damage. Comparative claims such as “greener” or “friendlier” need proof of an overall improvement, whether against competitors or your own previous product.
- L3: where scientific opinion is divided or evidence is inconclusive, say so, and do not imply universal acceptance.
- L4: do not suggest a product was changed to make it safe for the environment if it never caused harm in the first place.
- L5: avoid extravagant language and “bogus and confusing scientific terms”.
Appendix N extends Appendix L to motoring advertisements, which matters for anyone marketing electric or hybrid vehicles. Read it alongside our guide to car advertising rules in Singapore.
The Prism+ ruling: energy saving is not “saving the Earth”
The best-known Singapore example is the ASAS finding, reported in December 2023, against an Instagram ad for a Prism+ air-conditioner featuring the influencer Xiaxue. The ad said “Save Earth and electricity with 5 ticks energy savings”. ASAS found it breached the code’s rule against misleading advertising and asked for it to be taken down, taking the view that presenting an appliance’s energy efficiency as a benefit to the Earth was not acceptable, because the appliance still consumes energy.
The lesson is precise. The efficiency claim itself was fine; five ticks is an official rating. The problem was converting a relative efficiency benefit into an absolute environmental one. “Uses less electricity than a 2-tick model” survives. “Saves the Earth” does not. For the rules on how energy ratings must appear in ads, see our guide to energy label advertising in Singapore. And because the ad ran through an influencer, it is also a reminder that brand liability does not stop at your own channels; our influencer marketing guide covers how to brief creators on claims.
Common green claims, and how to fix them
Most green claims are not dishonest. They are lazy: a strong word standing in for a specific fact the brand actually has. The fix is almost always to replace the adjective with the fact.
| Risky claim | Why it is risky | Safer version |
|---|---|---|
| “Eco-friendly packaging” | Vague; Appendix L2 absolute term; principle 2 | “Box made from 100% recycled cardboard. Recyclable in the blue bin.” |
| “Made from recycled materials” | Misleading if only part is recycled (Guide Ex 3.10) | “Bottle made with 50% recycled PET. Cap is virgin plastic.” |
| “Biodegradable” | Misleading if it only breaks down in industrial conditions (Guide Ex 3.17) | “Breaks down in industrial composting facilities. Not suitable for home composting.” |
| “Sustainable cotton collection” | Misleading if the current line does not use it yet (Guide Ex 3.19) | “This line uses 40% certified organic cotton. Our target is 100% by 2028; progress reported yearly.” |
| “CFC-free” or “BPA-free” as a green headline | Meaningless if the attribute is mandatory or standard (Guide Ex 3.14) | Drop it, or state it as a spec, not a benefit |
| “Greener choice” | Comparison with no baseline (Guide Ex 3.15; Appendix L2) | “Uses 27% less plastic than our 2024 tray.” |
| Home-made leaf badge: “Eco Certified” | Self-declared label implying independent verification | Use a real scheme’s mark under licence, or remove the badge |
| “Carbon neutral delivery” | Needs evidence and material information on how it is achieved | “We offset the estimated emissions of each delivery through [named scheme]; method explained at [URL].” |
| “Net zero by 2030” | An ambition needs credible evidence of a plan (principles 1 and 5) | State the target, the baseline year, the scopes covered, and link to the plan and progress |
One note on that table: the CCS Guide does not expressly name “carbon neutral”, “offset” or “net zero”. Those rows apply its general rules on ambitions (principle 1), material information (principle 4) and evidence (principle 5), which is how CCS would be expected to assess them.
Images, colours and names count too
Because the test is the overall impression and the Guide lists images, symbols and brand names, green claims are not only words. The 2023 study counted irrelevant green imagery as a problem category: leaves, forests and globes on products with no environmental benefit. A product name like “EcoPure” or a leaf icon beside the price creates an impression you need to be able to support, exactly as a sentence would. Ask the creative team to treat the visual as a claim.
Where green claims hide in a marketing stack
Most businesses audit their packaging and forget everything else. In the accounts we work on, green claims surface in places the packaging review never sees:
- Marketplace listings. Titles and bullet points written for search (“eco friendly biodegradable reusable”) are claims. The study found marketplaces among the worst categories.
- Product feeds. Google Shopping and Meta catalogue attributes and custom labels can push “eco” into ad copy automatically.
- Paid social and creator content. Creators paraphrase. “Basically zero waste” in a TikTok voice-over is your claim if you paid for it.
- Sale campaigns. “Shop sustainably this 11.11” banners attach a green claim to an entire catalogue. Our mega-sale campaign guide covers the pricing rules that apply to the same banners.
- Search ads and SEO copy. Headlines optimised for “eco-friendly [product] Singapore” need a landing page that substantiates the phrase.
For online stores, green claims sit alongside the other product-description duties covered in our guide to the Trade Descriptions Act. A false statement of composition such as “100% recycled plastic” can be a false trade description under that criminal Act as well as an unfair practice under the CPFTA. Food brands should also read our guide to food advertising claims, and health and beauty brands our guide to health product advertising, because “natural” and “clean” claims there are governed by sector rules too.
Sector rules that sit on top
Listed and large companies: climate reporting
Corporate sustainability claims increasingly sit next to mandatory disclosures. Under revised timelines announced by ACRA on 25 August 2025, all listed companies report Scope 1 and 2 emissions from FY2025, and Straits Times Index constituents make full ISSB-based climate disclosures from FY2025, adding Scope 3 from FY2026. Other listed companies follow from FY2028 or FY2030 depending on market capitalisation, and large non-listed companies (revenue of at least $1 billion and total assets of at least $500 million) were deferred to FY2030. If your marketing says one thing about emissions and your annual report says another, the gap is visible to anyone who looks.
Ecolabels
If you want an independent mark, the Singapore Green Labelling Scheme, run by the Singapore Environment Council since 1999, describes itself as Singapore’s only ISO 14024-accredited Type 1 ecolabel, with more than 3,500 certified products. Whichever scheme you use, principle 4 applies: say which body certified what, and keep the certification current.
A green-claims checklist for marketing teams
- Inventory every claim. Packaging, listings, feeds, ads, creator briefs, website pages, sales decks. Include images, icons and product names.
- Replace adjectives with facts. Swap “eco-friendly” for what is actually true: the material, the percentage, the scheme.
- Scope every claim. Say whether it applies to the product, the packaging, one component, or the company.
- State the baseline for every comparison: compared with what, and when.
- Check supplier claims before repeating them; ask for the certificate or test report.
- Hold the evidence first, and keep it on file with the date it was checked.
- Verify certifications are current and that you are licensed to show the mark.
- Put qualifications where the claim is, not in a footnote. Use a URL or QR code only when space genuinely runs out.
- Brief creators in writing with approved claim wording, and review content before it goes live.
- Diarise a review whenever a product, supplier or target changes, and at least yearly.
Worked examples
A homeware brand on Shopee
A seller lists bamboo toothbrushes titled “100% Biodegradable Eco Friendly Bamboo Toothbrush”. The handles are bamboo; the bristles are nylon. The title fails principles 1 and 4: the product as a whole is not 100% biodegradable, and the material limitation is missing. A compliant title still ranks: “Bamboo Toothbrush, Compostable Handle, Nylon Bristles (Remove Before Composting)”. The search terms survive and the claim is now true.
A café’s reusable-cup promotion
A café runs a Meta ad: “Go green with us. Bring your own cup and save the planet.” The environmental benefit of a reusable cup depends on how many times it is reused, so “save the planet” is an absolute claim of the kind Appendix L2 and the Prism+ ruling warn against. The fix: “Bring your own cup and get 50 cents off. Every refill is one less disposable cup.” That is specific, true and still motivating.
Frequently asked questions
Is greenwashing illegal in Singapore?
There is no specific greenwashing offence, but a green claim that is false or likely to mislead a consumer is an unfair practice under the Consumer Protection (Fair Trading) Act 2003. Consumers can sue, and the Competition and Consumer Commission of Singapore can seek a court injunction. A false statement about the composition of goods can also breach the Trade Descriptions Act.
What is the CCS Guide on Quality-related Claims?
It is guidance published by the Competition and Consumer Commission of Singapore on 6 October 2025. It sets five principles for claims about a product’s qualities, uses or benefits, including environmental claims: claims should be true and accurate, clear, meaningful, accompanied by material information, and supportable by evidence. It is not binding law, but it shows how CCS reads the Act.
Can I describe my product as eco-friendly in Singapore?
Only with care. The advertising code’s Appendix L says absolute terms such as “environmentally friendly” should not be used without qualification unless there is convincing evidence of no environmental damage. It is safer to state the specific fact, such as the recycled content of the packaging.
Can CCS fine my business for a misleading green claim?
As at September 2026, the Act does not give CCS power to impose administrative fines for unfair practices. It can apply to court for a declaration or injunction, and breaching an injunction is contempt of court. Consumers can also claim up to $30,000 under section 6.
Do green claims made by influencers count?
Yes. If a creator makes the claim in content you paid for or directed, it forms part of your marketing and the overall impression it creates is attributed to you. The 2023 Prism+ case, an Instagram ad featuring an influencer, was treated as the brand’s ad.
Can I use a QR code instead of printing the details of a claim?
The CCS Guide accepts a URL or QR code for qualifying information where space is limited, but the information must still be clear and prominent. Hiding a material fact in small print can itself be an unfair practice.
The takeaway
Singapore has not banned green marketing. It has asked for green marketing that means something. The CCS Guide boils down to one habit: replace the adjective with the fact, scope it, and hold the evidence before you publish. Brands that do that lose nothing in persuasion, because “made with 50% recycled plastic” is more convincing to a sceptical shopper than “eco-friendly” ever was.
If you want your ads, listings and landing pages built on claims that hold up, that discipline is part of how our performance marketing team works; see our client case studies. Start with our guide to performance marketing in Singapore, and read this alongside the legal requirements for a Singapore website.
