Voluntary 'deforestation free' commitments

The document examines the application of the Unfair Commercial Practices Directive (UCPD) to corporate 'deforestation free' pledges, arguing that such commitments can be legally challenged if they are used in commercial practices to mislead consumers. It details the criteria for 'misleading' claims, the role of 'codes of conduct', and the enforcement mechanisms available in EU Member States.

• Voluntary 'deforestation free' commitments are subject to the UCPD only when they are made in the context of a 'commercial practice', such as on product packaging or in advertising, rather than as general public announcements.
• Environmental claims must be 'specific, accurate and unambiguous' and substantiated by scientific evidence to avoid being classified as misleading under UCPD guidance.
• Certain practices are 'blacklisted' and prohibited regardless of their impact on consumer decisions, including falsely claiming to be a signatory of a code of conduct or using a quality mark, such as the FSC logo, without authorisation.
• Broad, aspirational pledges like the New York Declaration on Forests or the Consumer Goods Forum (CGF) resolution are unlikely to be legally enforceable as 'codes of conduct' under the UCPD because they lack firm, verifiable terms and oversight mechanisms.
• Enforcement of the UCPD varies by Member State but is primarily handled by administrative authorities and consumer protection bodies, with remedies including cease and desist orders, administrative fines, and criminal sanctions.

APA

ClientEarth (2017). Voluntary 'deforestation free' commitments. https://www.clientearth.org/media/odlnucko/voluntary-deforestation-free-commitments-ce-en.pdf

Chicago

ClientEarth. Voluntary 'deforestation free' commitments. 2017. https://www.clientearth.org/media/odlnucko/voluntary-deforestation-free-commitments-ce-en.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=Voluntary 'deforestation free' commitments |date=April 2017 |url=https://www.clientearth.org/media/odlnucko/voluntary-deforestation-free-commitments-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2017voluntary, author = {{ClientEarth}}, title = {{Voluntary 'deforestation free' commitments}}, institution = {ClientEarth}, year = {2017}, month = apr, url = {https://www.clientearth.org/media/odlnucko/voluntary-deforestation-free-commitments-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }