On June 5, 2025, the Competition Bureau (the
"Bureau") released final enforcement
guidelines, ("Guidelines"), that set out
the Bureau's approach to the interpretation and enforcement of
environment and climate change related representations under the
Competition Act.
These Guidelines are the culmination of a significant
consultation process conducted by the Bureau. They are intended to
provide guidance in relation to the two new greenwashing provisions
introduced in June 20, 2024, that require a business to have
adequate and proper substantiation/testing prior to making certain
environmental and climate-change related
representations.1
The Guidelines seek to provide tools to businesses to allow them
to make environmental claims in compliance with the Competition Act
and address concerns raised in respect of the new greenwashing
provisions.2 While some argue that compliance with the
greenwashing provisions is relatively straightforward, this
position ignores the
