Claims & Compliance · ESCA × EDPA Sustainability Guidance
What never to say. What never to do.
This guidance was built because parts of our industry got this wrong. Vague claims, unverifiable numbers, language that couldn’t survive a single auditor question — that’s what erased trust. These are the rules that keep ours.
Before you publish any sustainability claim, ask yourself: “Could an independent third party verify this number in a week?” If the answer is no, rewrite the claim or drop it.
Because:
Say instead:
The seven greenwashing red flags
If a claim does any of these, it is greenwashing — even when made in good faith.
Adapted from TerraChoice (now UL), The Sins of Greenwashing (2010).
- · Is it a number? A claim without a number is a feeling.
- · Is the math showable? If you can’t hand someone the spreadsheet, don’t publish the claim.
- · Is the boundary named? “Our booth emits X” means nothing without: which show, which year, which scope.
- · Could you back it up if asked? If a client, regulator or court asked for the evidence, could you hand it over? The FTC expects a reasonable basis for an advertising claim before it is made, and so does this guidance.
- · Is there a date on it? Every claim expires. Say when it was measured.
The pre-publication gate
Before any public sustainability claim — website, sell sheet, RFP response, ESG disclosure, press release, LinkedIn post — it must clear every one of these gates. If any gate fails, the claim is not ready.
We recommend two sign-offs on every published claim: the person who did the math, and a second person (sustainability lead, legal or an executive) who checked the evidence. Keep a record of both with the claim. It is a simple check that stops a claim from traveling faster than its evidence.
If you cite someone else’s number
“Our partner says 60% recycled content” is not an excuse under the FTC Green Guides. When you quote a vendor, you adopt their claim. If it fails, you fail with it.
Ask the vendor for: (1) the underlying measurement, (2) the certification or test document, (3) the vintage (year measured), (4) the boundary (which product line, which plant), (5) a name willing to sign it. If they can’t produce all five in a week, don’t cite them.
If a claim you made turns out to be wrong, we recommend notifying every party that repeated it within 30 days and correcting the public record. It’s what separates an honest mistake from a coverup.
Know what’s coming, and keep the records that make your claims easy to support.
An updated, sourced version is coming soon. Nothing on this site is legal advice.
These practices can help you prepare for the requirements and requests listed below.
This is not legal advice.
The regulatory map
When the government knocks
An FTC inquiry, a state attorney general subpoena, a CSRD audit request, an SEC staff letter. The first question is always the same: “Show us the records behind the claim.” Here is what you must have ready to produce within 10 business days.
Claims-readiness self-check
A quick internal check of your claim practices. It is not a compliance audit or a legal opinion, and a high score doesn’t mean your claims are lawful.
Not legal advice. This self-check is educational and doesn’t certify compliance with any law.
Good records are the best protection: every number has a source, every claim has an evidence file, and every review has a date.
Speaks every standard your clients care about.
Complete one self-assessment here. Show your answers against whichever framework your exhibitor requires.
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