Brand Positioning
Part of DTC brand positioning
Writing product claims that can be supported: steps
Check a product claim’s wording, evidence, scope and overall impression before using it in DTC copy.
The Australian Consumer Law (ACL), part of the Competition and Consumer Act 2010, protects consumers and requires businesses to give truthful information about goods and services. The Australian Competition and Consumer Commission (ACCC) handles widespread issues, can require businesses to back up claims, and may investigate and take compliance or enforcement action.
Use four checks before publishing: classify the claim, match it to evidence, put its limits into the wording, and review the overall impression and product record. If the evidence does not support the wording, narrow the claim, obtain suitable proof or leave it out.
ACCC enforcement actions on misleading claims
- Regulator
- Australian Competition and Consumer Commission (ACCC)
- Enforcement power
- Require businesses to back up claims; may investigate and take compliance action
Classify the proposed statement
Start with the exact headline, caption or product-page sentence. Decide whether it is a specification, performance promise, comparison, environmental statement or prediction.
“Outer fabric contains recycled material” concerns a component, while “environmentally friendly bag” suggests a much wider benefit. Evidence for the first would not establish the second.
Read the images and nearby copy alongside the words. A photograph can suggest a use that the sentence avoids, and a qualification far below the headline may not correct the impression buyers take from the page.
Keep important limitations clear and close to the claim. The wording should make it apparent what the claim covers.
Match wording to evidence
Create a claim record before approving copy. Capture each claim separately so its wording and evidence can be checked together.
| Record | What to capture |
|---|---|
| Exact claim and placement | The words, image context and channels where they appear. |
| Product scope | The SKU, variant, component or version covered. |
| Support | The specification, supplier record, test or other suitable evidence and its date. |
| Conditions | The use, comparison basis or limits needed for the claim to hold. |
| Review responsibility | Who approves the wording and who rechecks it after a change. |
Depending on the claim, supporting material may include a bill of materials, lab report, certification number, calculation with its working, or supplier record. Match each item to the specific wording and product version; a supplier’s marketing PDF alone is not equivalent to supporting evidence.
A supplier record may support a composition statement if it reliably identifies the relevant component and version. A performance claim may need a suitable test of the finished item under relevant conditions; one kind of record does not automatically prove another kind of claim.
Write the boundary into the claim
For a hypothetical pouch, “the outer fabric contains recycled material” requires verified composition and clarity about the component covered. Evidence about one component does not establish that the whole pouch is sustainable.
For performance, say what the evidence established. If a test covered only a stated load, exposure or method of use, a promise covering every condition would go beyond that evidence.
For comparisons, check that the products, measures and dates are comparable. State the basis of the comparison clearly enough that buyers can understand what is being compared.
For a predicted future result, record the assumptions and evidence behind it. Qualify the wording where those assumptions limit the result, and do not present an uncertain outcome as certain.
For environmental wording, check the claim against ACL obligations and the ACCC’s “Environmental and sustainability claims” information. Keep the claim as narrow as the evidence: a component-level fact does not prove a broad environmental benefit.
Component vs. broad environmental claims
- Claim: Outer fabric contains recycled material
- Supported by verified composition of that component
- Claim: Environmentally friendly bag
- Requires broader evidence beyond one component; not supported by single fact
Review the full page and maintain the record
Read the headline, imagery, specifications, FAQ, packaging and advertisements together. Ask someone unfamiliar with the item what they expect it to do; their interpretation can expose unclear wording, but it is not proof of performance.
The ACCC’s “False or misleading claims” information says businesses may be required to back up their claims. If the page gives a broader impression than the supporting record, revise the prominent wording rather than relying on fine print.
Link each record to the product version and the copy buyers see, and keep superseded versions with their supporting evidence. Recheck affected wording when a supplier, material, design, test method or product version changes, including advertisements still in use.
