Green Claims Code: What It Means for Marketers

The Green Claims Code is the Competition and Markets Authority’s guidance on how a business can make environmental claims about its products, services or brand without misleading consumers. It applies to any suggestion that something is better for the environment, from “eco-friendly” on a product page to “carbon neutral” in an Instagram ad.

How the Green Claims Code works

The Competition and Markets Authority published the code in September 2021. It does not create a new law. It explains how existing consumer protection law applies to environmental claims, and sets that out as six principles. A claim must:

be truthful and accurate, and the business must actually live up to it;
be clear and unambiguous, so the meaning a shopper takes from it is the meaning you can support;
not leave out or hide important information, such as the fact that only one product line uses recycled material;
make only fair and meaningful comparisons, against like-for-like products and on a stated basis;
consider the full life cycle of the product or service, not just the one stage that looks good;
be substantiated, with current evidence you can produce when asked.

Since 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 has let the CMA decide for itself whether consumer law has been broken and fine a business up to 10% of its global turnover, without first going to court. Misleading environmental claims are an area it has said it will keep watching. Alongside it, the Advertising Standards Authority applies the CAP Code to environmental claims in ads, including paid social, search ads and the marketing claims on your own website.

ASA rulings show how the principles play out. Absolute terms such as “eco-friendly”, “sustainable” or “green” are read as meaning the product has no environmental impact, or an overall benefit, so they need a very high level of evidence and rarely survive on their own. “Carbon neutral” and “net zero” claims have been ruled misleading where the ad did not say the claim relied on offsetting, or did not make clear whether it covered the product, the delivery or the whole company. The ASA’s 2023 guidance on those terms asks advertisers to explain what the claim is based on.

Why it matters

Environmental claims influence buying decisions, so businesses want to make them. A café that switched to compostable cups, a cleaning company using plant-based products or a clothing brand using recycled fabric all have something worth saying. The risk is in the shorthand. A product page headline reading “100% sustainable” is a claim the CMA or ASA can ask you to prove, and an upheld ASA ruling is published on its website under your company name, where it can surface when people search for your brand.

It affects search copy too. The phrases people type, such as “eco-friendly cleaning products”, are often the same vague terms the code warns about. The answer is not to avoid the topic but to write specific, evidenced copy around those phrases, which tends to persuade better anyway.

Common mistakes

Using “eco-friendly”, “green” or “sustainable” as a general description with no qualification.
Claiming “carbon neutral” without saying that it depends on offsetting, or which part of the business it covers.
Calling packaging “recyclable” when most UK councils do not collect that material from homes.
Promoting one improvement, such as recycled packaging, while ignoring a much larger footprint elsewhere in the product.
Using leaves, forests or globes in the imagery to imply a benefit the copy never states and you cannot support.
Relying on a supplier’s assurance rather than holding the evidence in your own files.

How to act on it

Start with an inventory. List every environmental claim across your website, product feeds, ads, social posts and packaging, including imagery, badges and scheme logos. For each one, write down exactly what it means, the evidence behind it and the date that evidence was produced. This is the same discipline as substantiation for any objective claim in an ad.

Then rewrite. Replace “eco-friendly packaging” with what is actually true, for example “our boxes are made from recycled cardboard and can go in household recycling”, adding the percentage only if your supplier’s specification confirms it. Name any third-party scheme and link to its standards. Where a claim relies on offsetting, say so next to the claim, not in a footnote. Review the inventory whenever a supplier, material or process changes.

When I plan content and product page copy for a business that makes environmental claims, the claims inventory comes first, because rewriting fifty product pages after a complaint costs far more than writing them carefully once.

Do and do not

Do

Keep an inventory of every environmental claim and its evidence
Say exactly what a claim covers and how it was measured
Explain offsetting next to any carbon neutral claim

Do not

Use "eco-friendly" or "sustainable" without qualification
Imply benefits through imagery you cannot support
Rely on a supplier assurance you have not seen

Questions people ask about this

Is the Green Claims Code legally binding?

The code itself is guidance, not legislation. It explains how consumer protection law, now set out in the Digital Markets, Competition and Consumers Act 2024, applies to environmental claims. Because the CMA can enforce that law directly and impose fines, ignoring the code is a real risk rather than a matter of best practice.

Does the Green Claims Code apply to small businesses?

Yes. It applies to every business making environmental claims to consumers, whatever its size. The CMA's early investigations focused on large fashion retailers, but anyone, including a competitor, can complain to the ASA about a small firm's ad or website claim, and the ASA rules on those complaints in the same way.

Can I call my business carbon neutral if I offset my emissions?

You can, but the ad or page needs to say clearly that the claim relies on offsetting, what it covers and how it was calculated, and you need evidence of the offsetting scheme. The ASA expects that information to sit with the claim, not in small print elsewhere. A specific statement about the reductions you have actually made is often more convincing and easier to defend.

Green Claims Code

Quick facts: Green Claims Code