This is a Hong Kong-focused practical guide. Sources and limitations are listed at the end of the page.
Define the claim and its boundary
Terms such as “green”, “sustainable”, “recyclable”, “low carbon”, “net zero” and “carbon neutral” describe different things. Before publication, state whether the claim applies to the company, an operation, a product, a service, a package or a specific reporting period.
A reader should be able to understand what is included, what is excluded, the comparison basis and the conditions that must be met.
Build an evidence register
| Field | Record |
|---|---|
| Claim | Exact wording and channel. |
| Boundary | Entity, product, geography, life-cycle stage and period. |
| Method | Standard, calculation, test or certification used. |
| Evidence | Source documents, test reports, invoices, certificates and data files. |
| Qualifications | Conditions, exclusions, uncertainty and reliance on estimates. |
| Approval | Business owner, sustainability review, legal review where needed and publication date. |
| Refresh | Expiry date or trigger for reassessment. |
Treat carbon-neutral claims carefully
Distinguish actual emissions reductions from the use of carbon credits. State the emissions boundary, period, gross emissions, reductions achieved, residual emissions, credit quantity and type, retirement evidence and any exclusions.
Do not let an offset claim hide the footprint
Where the claim depends heavily on credits, explain that dependency clearly. Avoid implying that the underlying activity has no emissions or no environmental impact.
Use a controlled approval process
- The business owner proposes the exact wording.
- The data owner confirms the calculation and evidence.
- The sustainability team checks boundary, method and consistency.
- Legal or compliance review is obtained for higher-risk consumer or contractual claims.
- A named approver signs off the final version and refresh date.
Keep channels consistent
The same claim may appear in an ESG report, website, product page, packaging, tender, CDP response and financing document. Maintain one approved claim register so that updates and qualifications are applied consistently.
What to do when evidence is weak
Narrow the claim, add a clear qualification, change it to a factual description of the action, or do not publish it. A smaller claim that can be demonstrated is more valuable than a broad claim that cannot survive scrutiny.
Official sources
This page is grounded in the following official materials; requirements and market practice can change.
- Hong Kong Customs — unfair trade practicesThe Trade Descriptions Ordinance prohibits false trade descriptions and specified misleading practices in consumer transactions.
- Hong Kong Consumer Council — greenwashingConsumer guidance highlights vague environmental claims and the need for specific information and evidence.