The Canada Climate Law Initiative (CCLI) appreciates the opportunity to make recommendations to the Competition Bureau of Canada regarding the proposed guidelines on environmental claims under the Competition Act.

The CCLI has identified two areas of importance in the proposed guidelines. The first pertains to the clarification of the scope of the new provisions under the Competition Act. This clarification is a welcome and positive development, as it confirms that shareholder-focused disclosures are not subject to these provisions, unless used as promotional materials, providing much-needed clarity for companies. The second concerns the proposed guidelines’ lack of specificity, which risks creating uncertainty for companies navigating the updated regulatory framework.