This is Vinmonopolet

Guide to avoid greenwashing

This is Vinmonopolet’s guidance document on the use of sustainability claims on product packaging.
Malerull med grønn maling.

1.    Introduction

Many wholesalers that supply products to Vinmonopolet, label, or wish to label their products with various symbols intended to make a statement about the environmental properties of the products.

Labelling of products with various environmental symbols raises questions, both in relation to the alcohol advertising ban and the Norwegian Marketing Control Act. Therefore, there is a need to clarify what labels are in accordance with the regulations, what is not covered, and what we cannot accept.

2.    Legal basis in the Norwegian Alcohol Act and the Norwegian Marking Control Act

2.1.    The alcohol advertising ban

The alcohol advertising ban in Section 9-2 of the Norwegian Alcohol Act states that “Advertising of alcoholic beverages is prohibited. The prohibition also applies to the advertising of other products carrying the same brand or distinctive mark as alcoholic beverages.”

According to practice, it is permitted to apply objective, ordinary product information on the actual product, e.g., regarding alcohol content, bottle size and producer, as well as fact-based and objective flavour, use and storage descriptions. Other information will normally not be permitted, e.g., alcohol-favourable descriptions, review scores, awards etc.

2.1.1.    “General labelling schemes” are not affected by the alcohol advertising ban

Labels and symbols on the product are likely covered by the alcohol advertising ban, if they do not satisfy the special requirements in the exemption in Section 14-3, no. 18 of the Norwegian Alcohol Regulations which states that “[s]pecial labelling for general labelling schemes on the label or packaging of an alcoholic beverage, when the labelling documents that the product bearing the labelling fulfils special requirements regarding production method, origin or content” is not covered by the advertising ban.

Examples of general labelling schemes that are covered by this exemption are the Ø label (Debio), Spesialitet og Beskyttet betegnelse (Protected Designation). Corresponding foreign and international labelling schemes that set requirements for production method, origin or content will also be permitted.

Where a producer develops a labelling scheme for its own products, the producer is required to demonstrate that it is a “general labelling scheme”, in accordance with the Regulations. Vinmonopolet cannot approve the various labelling schemes but is required to discontinue the sale of products where we believe the requirement of a “general labelling scheme” has not been documented.

2.2.    The Norwegian Marketing Control Act

The Norwegian Marketing Control Act concerns the control of marketing, commercial practice and contract terms and conditions in consumer affairs and sets requirements for good business practice between commercial parties.

The Norwegian Consumer Authority is the supervisory authority in this regard and may submit cases to the Norwegian Market Council for decision. The Act prohibits unfair commercial practices in Section 6-9 and sets requirements for good marketing practice and documentation of claims used in marketing in sections 2 and 3, second paragraph, respectively, of the Act.

2.2.1.    Specific information regarding the duty to provide documentation

A fundamental principle in marketing law is the principle of truth. What is presented in marketing must be true and capable of being documented. This applies to all claims regarding factual matters, such as environmental claims.

Section 3, second paragraph is worded as follows: “Documentation shall be available to substantiate factual claims made in marketing, including as to the properties or effect of products. The documentation shall be in the possession of the advertiser at the time that the marketing takes place”. This provision is interrelated with the prohibition against misleading commercial practice: If a claim cannot be documented, it can easily be regarded as misleading.

2.2.2.    The Norwegian Consumer Authority’s guidance document

The Norwegian Consumer Authority has created a separate guidance document on the use of sustainability claims in marketing: Guidance on sustainability claims used for marketing purposes. The guidance document was developed for commercial parties who use environmental or ethical properties in products in marketing in relation to consumers, irrespective of sector. It applies correspondingly to claims regarding environmental matters concerning the entire undertaking, and not just individual products.

The guidance document states that “[i]n order for the documentation to have sufficient evidential weight, it is normally a requirements that the claims can be substantiated by statements or studies carried out by independent bodies with recognised technical expertise. This entails that studies that have been carried out by the producer or the undertaking that is marketing the product, must have been evaluated by an independent body or it must otherwise be possible to verify that the study has been correctly implemented and that the evaluation of the result can be justified on a purely technical basis.”

2.2.3.    Documentable factual aspects of the product

Use of symbols and environmental claims that only provide information about factual aspects of the product, e.g., recycled materials used, or the percentage of the product that is recyclable, will be in accordance with the Norwegian Marketing Control Act, insofar as such claims can be documented by an independent body possessing technical expertise. Here, however, a reservation must be made that consumers can easily perceive a product labelled with a reference to a property of its packaging as applying to the entire product and not just to the packaging. In such cases, Vinmonopolet will demand a clarification from the wholesaler.

2.2.4.    Stand-alone, unspecified sustainability claims

Labels, symbols and stand-alone sustainability claims that express that the product is, e.g., “climate neutral”, “carbon neutral”, “green”, “environmentally friendly” or similar will, according the Norwegian Consumer Authority’s guidance document be subject to a more comprehensive duty to provide documentation than claims consisting of objective and precise product information.

In order to cover the scope of such stand-alone, unspecified sustainability claims, the commercial party must, as a general rule, be able to document that the product is significantly less burdensome than other products in the same product category throughout its lifecycle (“from cradle to grave”). As a general rule, it will be misleading and in breach of the Norwegian Marketing Control Act to use claims as mentioned above, without at the same time providing an explanation as to which specific properties of the products the claims relate.

3.    Examples

Assessment of examples related to marketing of environment/sustainability on product packaging:

Part of a bottle label with the heading "Climate positive".

Not permitted

The product does not substantiate the claim (how it is climate positive) and appears to be without greenhouse gas emissions, which is impossible. Misleading in relation to customers.

Part of bottle label with text: 100 % recycled paper, 70 % recycled glass, 100 % recycled cardboard, 100 % pure vegetable ink."


Objective, factual information. Documentable via “technical sheet” or equivalent forwarded from the producer of the packaging.

Part of bottle label saying "Certified Carbon Neutral, carbonneutral.com".

Not permitted

This certification is not recognised (private label) and the product may appear environmentally superior compared to other products, without substantiating the claim. Presumably, it relates to carbon offsetting through the purchasing of carbon credits or similar.

Part of bottle label saying "Made of recycled plastic, 25 %, altiagroup.com."


Fact-based and specific communication that is acceptable.

Part of bottle label saying "Lighter glass bottle, 25 %, altiagroup.com".

Not permitted

25% lighter is a claim that has not been substantiated/documented. We cannot see what the product weighs in grams and cannot make an individual assessment of the claim. There is no standard for bottle weight on which to base the assessment and this will be misleading (the bottle is e.g., much heavier than a plastic bottle).
Part of bottle label saying "Carbin trust, CO2 measured."

Not permitted

“CO2 measured” is a claim without any additional, related information (what is the measured carbon footprint). Through such a label, the product may appear superior to other products and is therefore misleading.

Part of bottle label saying "carbon trust, reducing CO2".

Not permitted

The claim of “reducing” is not substantiated and we do not know in what way this product actually has a lower carbon footprint compared to other products.

The design of the symbol and its similarity to an ecolabel reinforces the misleading marketing.

Part of bottle label saying "Carbon trust, carbon neutral".

Not permitted

This certification is not recognised (private label, even though it is likely among the most widely used labels for carbon neutrality on our products) and the product may appear to be environmentally superior to other products without substantiating the claim. Presumably, it relates to carbon offsetting through the purchasing of carbon credits or similar.

The design of the symbol and its similarity to an ecolabel reinforces the misleading marketing.

Part of bottle label saying "Light weight bottle, 400 gr".


Fact-based information where the actual bottle weight appears as part of the symbol. Our definition of light weight, in collaboration with the Nordic alcohol retailing monopolies, is 420 grams. Thus, the label builds upon this understanding.