CCS Issues Guide to Help Businesses Make Clear and Accurate Product Claims

Introduction

On 6 October 2025, the Competition and Consumer Commission of Singapore (“CCS“) issued a guide titled “CCS Guide on Quality-related Claims” (the “Guide“) to help businesses make clear and accurate claims relating to the qualities, uses or benefits associated with their products (goods or services) or business.

The Guide sets out five key principles that businesses should refer to when making such claims and includes case studies to help businesses apply these principles in specific contexts.

The Guide was developed following concerns raised over potential greenwashing and recent enforcement actions taken by CCS against businesses found to have made misleading claims, e.g. misleading claims made by: (i) immigration consultancy businesses on the guaranteed success of applications made through them; (ii) beauty salons on the need for hair or nail treatment packages; and (iii) water filtration system sellers on the quality of their filtered water, or the quality of Singapore’s tap water. For more information on these matters, please refer to our March 2025 Legal Update titled “Consumer Protection in Singapore – Five Key Observations for Businesses in a Heightened Enforcement Climate” and our August 2025 Legal Update titled “Consumer Protection Enforcement and Regulatory Updates in Singapore“.

This Update highlights the key features of the Guide as well as its implications for businesses, particularly from a consumer protection regulatory and compliance perspective. This is especially important in light of CCS’ recent enforcement focus on false and misleading product claims, and the growing global scrutiny of greenwashing in marketing practices.

Key Principles in the Guide

The Guide appears to encourage wide applicability, stating that “quality-related claims”: (i) can be made through various means, including words, images, symbols, brand names, certifications, certification stamps or logos; (ii) can be included in all forms of marketing material to consumers in various forms of media (including traditional print media, online and social media); and (iii) can also be found on the goods themselves or any accompanying packaging. In making any quality-related claim, the focus is on the overall impression that a reasonable consumer will form from the information presented by the business.

True and Accurate Claims

1. True, accurate and updated claims: Businesses should ensure that the claims they make are true and accurate, and periodically review their claims to ensure that they remain true, accurate, and up-to-date. This includes claims that: (i) products or businesses are certified, conform to certain standards, or are approved by the authorities; and (ii) relate to sponsorships or affiliations. For example, a claim that a product has met certain industry standards, when the standard only applies to a particular component of the product, may be misleading and amount to an unfair trade practice under the Consumer Protection (Fair Trading) Act 2003 (“CPFTA“).

2. Verified claims: Further, businesses should take reasonable steps to verify the truth and accuracy of claims before communicating the same to consumers. They should also not refer consumers to general information or articles by third parties on particular attributes of their products, unless reasonable steps have been taken to verify that such information is true, accurate, and applicable to the product. For example, before representing to consumers that goods showcased in a “Choose Green” section of their stores are better for the environment and repeating claims made by upstream suppliers regarding these goods, businesses should take reasonable steps to verify that the claims made and supporting information provided by suppliers are true and accurate, and should further inquire with third parties if necessary.

3. Avoid overstating need: Businesses should also ensure that claims do not mislead consumers about the necessity of their products, and should not exaggerate the claimed quality, benefit or need of their products, without first establishing a reasonable basis for claiming the same. For example, a pedicure salon that informs consumers, based on visual inspections, that they have fungal infections and need anti-fungal treatments, without first assessing if the symptoms observed are indeed related to fungal infections, may have misled these consumers on the need for anti-fungal treatments, which amounts to an unfair trade practice under the CPFTA.

Clear and Easily Understood Claims 

1. Clear, specific and easily understood claims: Businesses should ensure that claims are clear, specific, and easily understood by the average consumer, given that vague, broad, and ambiguous claims are prone to overstatement or exaggeration as to the actual qualities, uses or benefits of the product. Plain and ordinary language should be used as far as possible.

2. Avoid technical jargon and self-declared labels: A key consideration is how the average consumer may understand the claim. Businesses should avoid using:

• • Terms, symbols and imagery in a different context from how they would be commonly understood by consumers, which may mislead consumers on the claimed or implied benefits of the product;
  • Technical jargon, which may be difficult for the average consumer to understand; and
  • Self-declared labels that lack independent third-party certification, which may mislead consumers into thinking that the products have been independently verified to meet certain standards.

For example, if a business claims that its bedsheet is “manufactured using environmentally sustainable Eco-soft Technology”, but that technology actually uses more environmentally harmful chemicals, the claim is likely to be misleading and to amount to an unfair trade practice under the CPFTA. In this regard: (i) the phrase “environmentally sustainable Eco-soft Technology” is not a conventionally used term; (ii) it is unclear what the bedsheet’s specific properties or environmental benefits are; and (iii) consumers are likely to interpret the phrase to mean that the production process has a lower environmental impact than conventional production processes when this is not actually the case.

Meaningful Claims

1. Material product attributes: Claims should be meaningful and helpful to consumers. Businesses should focus on material, non-standard and non-mandatory product attributes. For example, if a business claims that its product is “better for the environment” because it does not contain a particular chemical, but this chemical is prohibited by the authorities in any case, this claim is unlikely to be meaningful to consumers and should not be made.

2. Clear, fair and substantiable comparisons: Businesses should ensure that comparisons made with other products are fair and substantiable, e.g. they should make like-for-like comparisons and be prepared to specify the products they have made the comparison against if necessary. For example, if a business claims that its packaged salad is a “greener choice with 27% less packaging”, the claim is unlikely to be meaningful if the basis for comparison is unclear, e.g. whether the comparison is made against a previous version of the product or against competing products. The business should indicate the basis for comparison and be prepared to substantiate the comparison method and how it makes the product a “greener” choice.

Claims Accompanied by Material Information

1. Material information: Businesses should provide sufficient and material information to accompany their claims. This information should be provided in a prompt, prominent and easily accessible manner, and should include:

• • Limitations: Any assumptions, limitations or conditions underlying the claim. For example, if a detergent product is only biodegradable under specific conditions, this must be clearly stated to ensure that consumers understand the context and limitations of the claim;
  • Certifications: Information on any certifications referred to in the claim, e.g. the certification body, standards and criteria used. As a matter of good practice, businesses should opt for third-party certification schemes that are reputable, transparent, and based on robust certification criteria, such as those that apply globally recognised assessment methodologies; and
  • Benefits or outcomes: The key actions taken by the business to achieve any benefits or outcomes claimed to be delivered by the product. Businesses should: (i) avoid giving the impression that a benefit or outcome has been achieved, when it has not; (ii) clarify if the benefit or outcome will only materialise over a longer period; and (iii) reference recognised best practices, guidelines and standards relevant to the product or sector, where feasible.

2. QR/URL: If there is limited space on packaging, labels or marketing materials to set out qualifying or supporting information relating to any claims made, businesses should use a Uniform Resource Locator (“URL“) or Quick Response (“QR“) code to present such information. Businesses should avoid using small print to conceal material facts or mislead consumers as to material facts.

Claims Supportable by Evidence

Businesses should evaluate if they are able to reasonably substantiate their claims with valid, credible and up-to-date evidence, before making such claims.

1. Valid and credible evidence: Such evidence includes relevant and reliable evidence that is specific to the claimed benefit, impact or attribute of the products, e.g. tests, certifications, peer-reviewed research or objective studies conducted and evaluated by qualified persons using generally accepted scientific methods.

2. Claims on certifications: Claims on certifications obtained on products or the business should be substantiable with valid, credible and up-to-date evidence that is specific to the product or business relating to the claim, e.g. relevant evaluation reports and certifications issued by the certification body. Such substantiation should also be kept up-to-date with continuous and ongoing compliance with the certification scheme.

3. Claims on goals: Businesses that make claims on their ambitions and goals should ensure that they are able to demonstrate their intention and steps taken to achieve them with credible and corroborative evidence. If calculations or projections on targets and performance are made, businesses should use internationally recognised assessment and accounting methodologies and ensure that the assessment and accounting is periodically reviewed and up-to-date.

4. Reasonableness: The reasonableness of a business’ actions will be assessed with reference to: (i) the size of its operations; (ii) its relative position in the supply chain; (iii) any claims made to it by another supplier; and (iv) the resources available to it.

Consumer Protection Regulatory and Compliance Implications

While the Guide should not be seen as a substitute for the CPFTA and does not set a limit on CCS’ investigations and enforcement actions, businesses should nevertheless adhere to the broad guiding principles it sets out, bearing in mind that making misleading or false claims can constitute an unfair trade practice under the CPFTA.

Indeed, the Guide serves as a key reference to ensure that product claims are both consumer-friendly and legally compliant, which is particularly relevant for businesses in the current climate, given CCS’ enforcement actions against misleading or false quality-related claims, as well as its 2023 study on greenwashing in online marketing.

Businesses should seek professional legal advice if they are unsure whether their actions may constitute unfair trade practices under the CPFTA. They may also refer to resources provided by the Consumers Association of Singapore (“CASE“) or the Advertising Standards Authority of Singapore (“ASAS“) for guidance on such matters.

Conclusion

From a compliance perspective, the Guide underscores the importance of robust internal compliance frameworks for businesses making product claims, e.g. by ensuring that all marketing and advertising materials are regularly reviewed and updated to reflect accurate, clear, and substantiated information, implementing processes to verify the accuracy of claims made, maintaining up-to-date evidence to support those claims, and training staff to understand the relevant requirements. 

From a commercial standpoint, adhering to the Guide’s principles not only mitigates legal and compliance risks, but also enhances consumer trust and brand reputation. Transparent, meaningful, and evidence-based product claims can differentiate a business in a competitive marketplace, fostering long-term customer loyalty and confidence. Conversely, businesses that fail to substantiate their product claims or that exaggerate product benefits risk eroding consumer confidence and may face complaints made to CASE or ASAS. Ultimately, businesses are encouraged to view adherence to the Guide, not merely as a matter of compliance, but as a strategic opportunity to build credibility and trust with consumers in Singapore. 

Rajah & Tann’s multi-disciplinary team is well-placed to advise on issues involving consumer protection law and its application to product claims. For businesses interested in ensuring that their product claims adhere to the CPFTA and the Guide, please do not hesitate to reach out to our Team members set out on this page.