The UK’s Competition and Markets Authority (CMA) published the Green Claims Code in September 2021 to set out its view of how existing consumer protection law applies to environmental claims. The Code doesn’t create new law — it clarifies how the CMA expects businesses to comply with the law that already exists, and it gives companies a practical framework for making sure their sustainability marketing holds up to scrutiny.
At its core, the Code is built around six principles: green claims must be truthful and accurate; clear and unambiguous; must not omit or hide important relevant information; must only make fair and meaningful comparisons; must consider the full life cycle of the product; and must be substantiated. Any business making an environmental claim — whether on packaging, in advertising, or on an online marketplace — is expected to test its claims against all six. Below, we break down what the Code covers, why it exists, and what each principle means in practice, including how Life Cycle Assessment (LCA) evidence fits into substantiating a claim.
What is a Green Claim?
Green claims are “claims that show how a product, service, brand or business provides a benefit or is less harmful to the environment”.
Who does the Green Claims Code apply to?
All businesses making environmental claims whether on packaging or in advertising and online marketplaces.
Why does the Green Claims Code exist?
- Tackling ‘Greenwashing’: the process of conveying a false impression or providing misleading information about how a company’s products are more environmentally sound
- Helping businesses comply with existing obligations under consumer protection law
- Supporting the government’s sustainability goals
When did the Green Claims Code come into force?
The Competition and Markets Authority (CMA) published the Green Claims Code in September 2021 and announced that it is focusing its efforts into looking into green claims by FMCGs in February 2023.
What is the risk to me and my business if I don’t comply?
- Reputational Harm: Impact on your sustainability reputation. Partnerships and sponsorships may be put in jeopardy
- Enforcement: CMA can fine companies 10% of global turnover. Trading Standards can pursue criminal enforcement
The Green Claims Code: The Six Principles in Practice
Green claims MUST:
1. Be truthful and accurate: Businesses must live up to the claims they make about their products, services, brands and activities. In practice, this means a claim like “carbon neutral” or “recyclable packaging” needs to reflect what actually happens, not an aspiration or a best-case scenario. If a claim depends on conditions that rarely apply — a package that’s only recyclable in facilities most consumers don’t have access to, for example — it isn’t accurate as stated. Businesses should be able to point to the specific data or process behind every word used in a claim.
2. Be clear and unambiguous: The meaning that a consumer is likely to take from a product’s messaging and the credentials of that product should match. A claim can be technically true and still misleading if it’s phrased in a way that most people would read as meaning something bigger. Terms like “eco,” “green,” and “sustainable” carry a lot of implied weight for consumers, so businesses need to be precise about what the claim actually covers — a single ingredient, a specific process, or the whole product — rather than letting vague language do the work.
3. Not omit or hide important information: Claims must not prevent someone from making an informed choice because of the information they leave out. This is often where well-intentioned claims run into trouble: a product might genuinely use less plastic than a previous version, but if it has a materially higher carbon footprint elsewhere in its life cycle, leaving that out paints an incomplete picture. Important context — caveats, exceptions, or trade-offs — needs to be presented alongside the claim, not buried in a footnote or omitted from marketing copy entirely.
4. Only make fair and meaningful comparisons: Any products compared should meet the same needs or be intended for the same purpose. Comparative claims (“30% lower emissions than our previous packaging,” “greener than the leading brand”) need a like-for-like basis: same functional unit, same system boundaries, and ideally the same measurement methodology. Comparing a cradle-to-gate figure for one product against a cradle-to-grave figure for another, for instance, isn’t a fair comparison even if both numbers are individually accurate.
5. Consider the full life cycle of the product: When making claims, businesses must consider the total impact of a product or service. Claims can be misleading where they don’t reflect the overall impact or where they focus on one aspect of it but not another. A product that reduces emissions during manufacturing but increases them in transport, use, or disposal hasn’t necessarily reduced its overall footprint. This is precisely the principle where a properly scoped Life Cycle Assessment (LCA), conducted in line with ISO 14040/14044, becomes essential — it’s the tool designed to capture impacts across the entire life cycle rather than a single stage.
6. Be substantiated: Businesses should be able to back up their claims with robust, credible and up to date evidence. “Robust” and “credible” set a real bar: internal estimates or marketing-team assumptions won’t satisfy it. This is where LCA-based evidence, calculated using recognized databases like ecoinvent or GaBi and following the GHG Protocol for Scope 3 accounting, gives a claim genuine substantiation. A Product Carbon Footprint (PCF) or an Environmental Product Declaration (EPD) built on primary data and a recognized methodology gives a business a defensible, auditable basis for a claim — and evidence that stays current, since the Code also expects substantiation to be kept up to date as products, supply chains, and processes change.
Examples of general claims which are likely to be misleading unless a full lifecycle claims is provided:
X Good for the planet.
X Good for the land.
X Helping to support a more sustainable future.
X 100% eco-friendly.
X Environmentally friendly.
X Zero emissions.
X Give back to the environment.
X Less plastic.
General claims like these should not be used without qualification unless marketers / broadcasters can provide evidence to demonstrate that the claim applies to the entire lifecycle of the product or service, from manufacture to disposal.
Key Take Aways
1. Consider the full lifecycle impact first
2. Consider what evidence you have to substantiate your claim, check if it relates to a specific part of the life cycle
3. Be careful about omitting information that affects the consumer’s ability to make an informed choice
4. Consider whether your claim is too broad/vague or the basis is unclear
5. Consider the overall impression that your claim will have on your customers
6. Consider that this is a developing area – previously approved claims may need to be reviewed in light of developments
For businesses making sustainability claims, the practical takeaway is that credible evidence needs to come first, not last. Building an LCA or PCF into your process before you finalize marketing language means every claim is grounded in life cycle data from the outset, rather than being retrofitted with justification after the fact. You can learn more by visiting the CMA Green Claims Code website.
