Public Comments on the Ministry of Environment’s proposed revisions of the Environmental Claims Guidelines

ClientEarth Japan submitted its public comment in March 2026 in response to the Ministry of the Environment’s call for public opinions which was launched on 16 February 2026, regarding the proposed amendments to the “Environmental Claims Guidelines.”

In Japan, public interest in greenwashing has grown rapidly. At the same time, globally, regulations against greenwashing have advanced significantly, and the standards of transparency and accuracy required for corporate environmental claims are becoming increasingly stringent. In particular, regulatory developments in the EU are already directly affecting Japanese companies operating internationally. Environmental claims that fail to align with international standards risk undermining corporate credibility and competitiveness.

Against this backdrop, the newly released amendment proposal represents an important opportunity to reassess the role and structure of environmental claims in Japan. However, the proposal does not sufficiently reflect international discussions, case law and the broader trend of regulatory tightening. As a result, there remain several areas where improvements are needed to protect consumers and ensure a fair and transparent business environment.

ClientEarth submitted the following public comment with the aim of helping this amendment develop into a truly effective framework. Our submission wishes to ensure environmental claims in Japan are transparent, consistent with international norms and aligned with global expectations.

This submission focuses in particular on issues widely debated in the global climate change context and addresses the following five key points concerning challenges and necessary improvements in the proposal:

1. International Regulatory Developments

The proposal does not adequately reflect international examples of greenwashing or the growing trend of regulatory tightening. As a result, even if Japanese companies comply with the revised guidelines, their environmental claims may still fail to meet the stricter scrutiny applied overseas.

2. Carbon Offset–Based Claims

Claims of carbon neutrality or similar assertions based on carbon offsets conflict with internationally accepted views that such offsets merely address emissions outside a company’s own supply chain and are not equivalent to reducing emissions within the supply chain of a product or service.

3. Forward‑Looking Statements Such as Net‑Zero Targets

Internationally, net‑zero targets or other future-oriented claims that lack reasonable grounds, concrete plans or alignment with corporate realities are considered misleading. The amendment proposal does not address such forward‑looking statements.

4. Regulation of Advertising Related to Fossil Fuels

Japan continues to have a high dependence on fossil fuels, and marketing that suggests fossil fuels are clean is widespread. While many jurisdictions are strengthening regulations on fossil fuel advertising itself, the proposal should contain robust warnings regarding environmental claims related to fossil fuels.

5. Corporate Stance and Image Advertising

Japan’s Act against Unjustifiable Premiums and Misleading Representations regulates only advertising related to specific products or services. It therefore cannot address greenwashing found in corporate stance statements or image advertising, such as those mentioned in point 3 above.

ClientEarth hopes that this submission will contribute to the sound development of environmental claims practices in Japan and support the creation of a fair, transparent market that advances the transition to a sustainable society.

You can access the submitted public comment here.