Green Claims Code: how to avoid greenwashing in UK environmental claims
The CMA's Green Claims Code (CMA146) sets out how it thinks consumer protection law applies to environmental claims on goods and services. This page summarises its six principles and the claims it singles out as risky.
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The six principles
In the CMA's view, environmental claims must be truthful and accurate, be clear and unambiguous, not omit or hide important information, make fair and meaningful comparisons, consider the full life cycle of the product or service, and be substantiated.
The principles work together and more than one will usually apply. The CMA notes that businesses that do not follow them are more likely to attract its attention, and that a court or enforcement body may require evidence to back up a claim.
Claims that often cause problems
Terms like 'green', 'sustainable' or 'eco-friendly', especially without explanation, are likely to suggest that a whole product or business has a positive environmental impact, or at least no adverse one. In one CMA case study, an energy supplier's 'Go 100% green' and 'save the planet' slogans are treated as broad, absolute claims that need a high level of substantiating evidence.
'Recyclable' claims also need care. Labelling a product 'recyclable' when only the packaging is, or when some parts prevent recycling, risks misleading consumers. The whole life cycle counts too: one CMA example is an 'eco shampoo' sold in a box with green rainforest imagery, which is misleading because raw materials shipped from the Amazon and other stages of its life cycle have adverse environmental effects.
Frequently asked questions
Can I just say a clothing range is now 'greener'?
The CMA gives this as an example of a comparative claim that is unlikely to be fair and meaningful on its own. Comparisons should make clear what is compared and how, use the same measures, and be backed by transparent evidence consumers can verify.
Can a claim be misleading even if it is factually true?
Yes. The Code says claims must not mislead by giving an inaccurate impression, even when they are factually correct. Presenting a feature that is standard or legally required as a special environmental benefit is one example.
What should I say about carbon neutral or net zero claims?
The Code says such claims should include accurate information about whether, and to what degree, the business is actively reducing the emissions of its products or services or offsetting them. The full life cycle principle also applies.
Does the Green Claims Code also matter for influencers?
The CMA's guidance for content creators says not to claim something is eco-friendly if you cannot prove it. Creators promoting a product are expected to avoid false or unsupported statements in the same way.
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claude mcp add --transport http kopik-uk-cma-consumer-law-reviews-influencers-green-claims "https://kopik.io/api/mcp?base=uk-cma-consumer-law-reviews-influencers-green-claims" --header "Authorization: Bearer kpk_…"{
"mcpServers": {
"kopik-uk-cma-consumer-law-reviews-influencers-green-claims": {
"url": "https://kopik.io/api/mcp?base=uk-cma-consumer-law-reviews-influencers-green-claims",
"headers": {
"Authorization": "Bearer kpk_…"
}
}
}
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-H "Authorization: Bearer kpk_…" \
-H "Content-Type: application/json" \
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