green claims

How to use the Green Claims Code in business

The Green Claims Code has come into force, meaning companies making sustainability and environmental claims should review their announcements. Marketing and PR teams will need to take notice of what the Green Claims Code means for their communication work.

The code has been introduced to stem the tide of greenwashing, the process of conveying a false impression or providing misleading information, presenting a company’s products as more environmentally sound than they truly are.

Companies that are found to be greenwashing may end up in the firing line of the Competition and Markets Authority (CMA). They are breaking consumer protection law.

It’s therefore imperative that sustainability information distributed by your company is accurate and true and none of the statements made are misleading.

Development of the Green Claims Code

The Code has been introduced following the CMA’s discovery that around 40% of businesses’ claims around their environmental work were misleading consumers. More and more companies are adding green or positive environmental claims to their products and services, hoping that this will help them to secure more business or attract more ethically-minded consumers.

Announcing the code in September, Minister of State for Energy and Clean Growth, Greg Hands, said: “Millions of UK households are rightly choosing to switch to green products as they look to reduce their carbon footprint. But it’s only right that this commitment is backed up by transparent claims from businesses.

The competition regulator’s new code will help to ensure this with advice on how best to communicate and understand environmental claims.”

Claims include suggesting that buying a certain product will result in reduced packaging pollution, or that your item was produced more sustainably than your competitors’ product. Consumers have seen these announcements in all areas, from cleaning products to tech services to beauty supplies and clothing.

The CMA has found that these environmental claims are often unsubstantiated or inflated.

What are misleading environmental claims?

Environmental claims are ones that tell consumers that their product, service, process, brand or business is good or better for the environment, possibly more than other ones. They suggest that a product or a service:

  • has a positive environmental impact or no impact on the environment;
  • is less damaging to the environment than a previous version of the same good or service; or
  • is less damaging to the environment than competing goods or services.

All aspects of a claim may be relevant, such as:

  • the meaning of any terms used;
  • the qualifications and explanations of what is said;
  • the evidence that supports those claims;
  • the information that is not included or hidden;
  • the colours, pictures and logos used; and
  • the overall presentation.

When a claim is genuine, it properly describes the impact of the product, service, process, brand or business, and do not hide or misrepresent crucial information. Of course, some sustainability claims are real and true, but it is increasingly difficult for consumers to tell the difference between genuine statements and misleading green claims.

Misleading environmental claims happen where a business gives the impression that their products and services are less harmful or more beneficial to the environment than they really are. Businesses may not realise they are falling foul of consumer law, so the Green Claims Code was introduced in order to make more information available on this issue and protect both consumers and businesses.

The Green Claims Code guidance

The CMA is focusing on fashion and fast-moving consumer goods to start. But don’t think that other businesses can wait. The Green Claims Code guidance applies to every company. Non-consumer facing and services businesses also need to check their claims that relate to sustainability. Every business should review their environmental claims and ensure that they are meeting their obligations.

Not doing so could result in fines for breaking consumer protection law.

What does the Green Claims Code mean for my business’s PR campaigns?  

The CMA’s criteria state that all environmental claims must be truthful and accurate; unambiguous; substantiated and consider the full life cycle of the product or service.

If businesses are comparing themselves to similar companies, then any comparisons of services and products must be fair and use the same measurements. For example, if you are claiming that your shampoo is the greenest product on the market: which feature are you referring to? Is it the materials used to make the shampoo? Or the process by which it was made? Or the way it is packaged, distributed and marketed? Fair and meaningful comparisons must stand up to scrutiny, and consumers must be able to verify this information for themselves, if they wish to do so.

Your business cannot fall foul of the CMA’s requirements. Even if the Code doesn’t seem to be relevant for your company now, it is well worth understanding the rules.

Here are some steps that could be helpful as companies seek to change their operating models and principles to become more sustainable.

  1. Understand your environmental claims 

Look inwards and understand just how sustainable your business really is. Review the claims made by your company relating to the environment, sustainability, carbon emissions or your socially responsible actions.

This should be thorough and cover every part of the company, including packaging, marketing materials and website copy.

Your review should encompass visual representations as well as text, as these can be considered as environmental credentials. If you use a recycling icon to illustrate a product when the entire product is not recyclable, the icon could be an infringement as you are making misleading environmental claims for the consumer.

B2B companies should be wary of using words such as ‘green’, ‘sustainable’ or ‘eco-friendly’. The Code states that terms such as these may suggest that a product or service has a positive environmental impact or “at least no adverse impact”. To meet the Green Claims Code, words and claims such as these must be true and can be proved. Otherwise, the company or product might not meet legal obligations.

  1. Check your language and links  

Once you understand how sustainable your business is and where the references to sustainability and the environment are located, ensure the information shared with your audiences uses the right language and can be verified.

As mentioned above, all claims must be substantiated. Add a single click-through link to provide clarifications where you are making claims about green credentials. Link to credible and external sources where possible.

There are implications here for content, design and website structure too. The code requires information on sustainability to be easy to find, and a lack of space is not considered justification for missing relevant information.

Review all links in your business’s communications that relate to sustainable and environmental work, products or services. Proof points are needed to substantiate all the claims made and so this may require new designs, marketing materials and potential edits to past materials. While this may seem like a lot of work the process may spark ideas, and will crucially ensure that you don’t mislead consumers.

  1. Train your team 

Ensuring compliance with the Green Claims Code is not a one-off process. Across any sector, the number and nature of references to sustainability will change over time. Invest in training for all employees and check they understand the requirements regularly.

It is not enough for senior leadership to understand the importance of making accurate environmental statements. Marketing, communications, compliance, product development teams should grasp it too.

Providing training will help ensure that future materials are appropriate under the Green Claims Code. Training product and marketing teams to understand that language must be specific and as objective as possible will likely be a worthwhile long-term investment as more and more businesses comply with the requirements.

  1. Invest in outside help and accreditation  

Preparing for the CMA’s Green Claims Code may appear daunting. However, consider this as part of your wider ESG and Sustainability strategy, as well as part of legal compliance. Membership of industry-specific organisations and accreditation via cross-sector schemes such as BCorp can help you to ask the right questions about your green claims.

The BCorp movement is becoming more and more prevalent. The process itself is a rigorous one, you can find out more about what it involves via this helpful article from Startups Magazine.

The CMA’s rules may only apply in the UK but there are signs that other jurisdictions are also going to follow suit.

The introduction of the Green Claims Code is also an opportunity to refresh your ESG & sustainability messaging, so also consider outside ESG communications support to ensure your PR strategies are fit for purpose.


Find all resources and relevant information about the Green Claims Code here.