Japan Publishes Revised “Environmental Labeling Guidelines” to Strengthen Measures Against Greenwashing 
On March 31, 2026, Japan’s Ministry of the Environment (MOE) released a revised edition of the “Environmental Labeling Guidelines”, which organize the appropriate approach to providing environmental information for businesses that make self-declared environmental claims. The revision responds to the growing domestic and international attention on expanding the market for green products and addressing greenwashing claims of environmental friendliness that lack substantive basis. The purpose of the revision is to help Japanese companies communicate their environmental initiatives appropriately and support the development of a greener economic system. Key updates include a reorganization of the “Five Basic Principles” that businesses must follow at minimum, the addition of illustrative examples of advertising claims, and the incorporation of recent regulatory trend.
Reorganization of the “Five Basic Principles” for Appropriate Labeling
The following Five Basic Principles were established as requirements for businesses:
- Avoid vague expressions or environmental claims
Present environmental claims in quantitative terms. - Provide explanatory text for environmental claims
Clearly identify the basis of comparison. - Consider the entire product life cycle-including potential negative impacts, not only positive aspects
Confirm that the claimed environmental improvement does not create significant trade-offs in other areas. - Ensure that data and evaluation methods necessary to verify environmental claims are available and accessible
For example, include a QR code on product packaging to provide easy access to supporting data and evaluation methods. - Ensure that comparative claims about products or processes are based on LCA (Life Cycle Assessment) or numerical data
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- Present percentages or absolute values to enable comparison.
- Claims about product improvements and packaging improvements must be made separately.
A notable change is the addition of “consideration of the entire life cycle” as a new basic principle, reflecting regulatory trends in the EU. Each principle is now accompanied by illustrations to facilitate intuitive understanding.
Clarification of Scope
The Guidelines now explicitly state that their scope includes not only representations related to transactions of goods covered by the Act against Unjustifiable Premiums and Misleading Representations, but also environmental claims unrelated to direct product transactions—such as claims about business activities, image advertising, and corporate posture.
Addressing New Types of Environmental Claims and Methods (Carbon footprint, carbon offset, etc.)
The revision clarifies that claims related to the carbon footprint of products (CFP) and carbon offsets must comply not with ISO/JIS Q 14021 but with their respective specialized guidelines and ISO standards. Reference columns have been added for further guidance.
Claims Related to the Carbon Footprint of Products (CFP)
CFP refers to the greenhouse gas emissions associated with a product or service throughout its entire life cycle—from raw material procurement to disposal or recycling—expressed as CO₂ emissions. Claims regarding CFP must comply with the Carbon Footprint Communication Program Guidelines (Ministry of the Environment, MOE, and Ministry of Economy, Trade and Industry, METI) and ISO 14067. Five basic principles for CFP labeling are identified: reliability and credibility, life cycle perspective, comparability, transparency, and regional relevance.
Claims Related to Carbon Offsetting
Carbon offsetting involves recognizing emissions, making proactive efforts to reduce them, and compensating for emissions that are difficult to eliminate through carbon credits or similar mechanisms. Claims must not be used to justify a failure to reduce emissions directly. Businesses must follow appropriate ISO standards, etc, such as “Guidance on Carbon Offsetting in Japan” and ISO 14068-1.
Mass Balance Method
The mass balance method, used in plastic resource circulation and similar contexts, allocates the characteristics of recycled raw materials when they are mixed with conventional raw materials during production. Even when physically mixed, a portion of the final product may be treated as an “eco-friendly product” based on the amount of recycled material initially introduced. However, because the environmental value may be difficult to discern compared with actual usage—such as when the allocation does not match the physical mixing ratio—appropriate labeling and communication tailored to product characteristics are necessary. This point is explained in an added reference column.
Separate Supplement on Overseas Greenwashing Regulations
Given the increasing number of greenwashing-related lawsuits and strengthened regulations in the United States, the EU, and elsewhere, the revised Guidelines include a separate supplement dedicated to overseas regulatory trend. This structure allows for timely updates to rapidly evolving foreign regulations and case examples.
EnviX Comment
Under the EU’s Unfair Commercial Practices Directive, claims that a product is “environmentally neutral or positive” based on greenhouse gas offsetting are considered unfair commercial practices. As a result, Japanese companies operating globally face the risk of being criticized as engaging in greenwashing overseas, even if they meet domestic standards, when relying too heavily on offsets. Going forward, effective environmental communication will require companies to first take concrete steps to reduce emissions across the entire product life cycle. When offsetting residual emissions, companies must disclose transparent and objective evidence to earn trust in both domestic and international markets.
Reference URLs
MOE press release on the revision of the Environmental Labeling Guidelines (March 31, 2026)
https://www.env.go.jp/press/press_03660.html
Environmental Labeling Guidelines (March 2026 edition)
https://www.env.go.jp/content/000390026.pdf
“Study Group on Environmental Labeling”
https://www.env.go.jp/policy/hozen/green/g-law/net/page_00094.html
