In the new code published by the CAP, and which comes in force in September this year, the claim that e-billing is environmentally more sustainable than traditional printed bills will now need to be substantiated with much greater information about the total life cycle of the e-billing process.
So far it has been easy to claim that by reducing paper usage there is a environmental benefit but such claims have always avoided any examination of the total IT costs involved in e-communication such as electronic equipment, manufacture and disposal, which is today coming under much greater scrutiny. See Greenpeace action on Facebook's new server farm, and also Greenpeace concerns over e-waste.
And those encouraging e-billing do not take account of the number of people printing out their bills at home, at a higher environmental cost per item than a centrally produced printed bill.