Summary
Details
- The United Kingdom
- Global
The Green Claims Code applies to any business that markets goods or services to UK consumers and makes environmental claims. It covers UK-based and overseas businesses, of any size and in any sector—including manufacturers, wholesalers, distributors, retailers, and online marketplaces. It applies to product-, service-, and brand-level statements and to all forms of presentation (ad copy, packaging, labels, logos, imagery) as well as comparisons, whether with competitors or with a company’s own previous models.
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Introduction
The Green Claims Code (GCC), published by the Competition & Markets Authority (CMA) in September 2021, guides businesses on making environmental claims that comply with consumer law and avoid greenwashing. It distils six principles: be truthful and accurate; clear; don’t omit material information; make fair comparisons; consider lifecycle where relevant; and substantiate. Before the GCC, enforcement rested on core consumer-protection rules, especially the Consumer Protection from Unfair Trading Regulations 2008 (CPRs) supported by official guidance from the (then) Office of Fair Trading and the Business Department on how the CPRs apply. Sector-agnostic DEFRA Green Claims Guidance (2011) also set best-practice principles for clear, accurate, substantiated environmental claims. The GCC applies across media (packaging, websites, ads, labels, imagery) and sits alongside advertising rules enforced by the Advertising Standards Authority (ASA). In practice, it sets the yardstick the CMA and ASA use when assessing alleged “greenwashing.” Since April 2025, the Digital Markets, Competition and Consumers Act 2024 has given the CMA direct consumer-law enforcement powers (including the imposition of fines of up to 10% of companies' turnover), further raising the stakes for poor claims
Implications for Environmental/Climate Reporting
At its core, the GCC is not a stand-alone emissions-reporting regime. It only requires that if businesses make green claims about a product, they must hold credible evidence for it and avoid hiding material facts. That has real implications for environmental/climate data and governance. In practice, businesses should:
Measure what you claim (e.g., product carbon footprints, recycled content, and water impacts) and retain files that show scope, boundaries, baselines, dates, methods and sources.
Substantiate neutral, low-carbon, recyclable, biodegradable, or comparative claims with robust, up-to-date evidence; consider whole-lifecycle where relevant.
Be transparent at the point of claim and be ready to provide substantiation to CMA/Trading Standards (and to the ASA for ads) if asked.
Helpful software for managing claims and substantiation:
CarbonCloud — Product Climate Footprint (PCF) platform with explainers on aligning label use and claims with the Green Claims Code. Useful where green claims depend on carbon footprints.
Provenance — Claims management stack with a Green Claims Checker aligned to standards/regulators (CMA/ASA, EU, FTC, ACCC) and a framework for evidencing and publishing claim “Proof Points.”
Bottom line for businesses: the GCC indirectly demands solid environmental data and controls if you choose to make green claims and regulators expect you to have that evidence on file.
Enforcement Action
Regulators use the GCC as the yardstick for consumer-law enforcement. These recent CMA actions show how it’s being applied.
ASOS, Boohoo & George at Asda (March 2024): CMA closed its probe with binding commitments requiring clearer, specific claims, evidence on targets, accurate filters, and regular compliance reports. The case page and press notice tie outcomes to the Green Claims Code and sector guidance.
Unilever — Investigation closed in Nov 2024 after Unilever made changes to initial green claims about some of its household products.
Open letter to the fashion sector: Published in March 2024 alongside the ASOS/Boohoo/Asda undertakings and explicitly frames expectations through the GCC and urges the wider sector to align practices.
Current Status and Outlook
Today, the GCC remains the UK’s reference point for green claims under consumer-protection law and ASA ad rules. The CMA’s new powers (since 6 April 2025) mean potential direct fines for businesses of up to 10% of their turnover and redress for misleading claims, so internal governance and documentation matter more than ever. CMA enforcement has moved from sector sweeps (e.g. fashion and FMCG) to case-by-case changes and undertakings, while the Advertising Standards Association (ASA) keeps banning ads it finds misleading, especially in high-emitting sectors and where claims lack clear context or substantiation. Businesses can expect continued focus on vague “sustainable/eco-friendly” language, comparatives, offset-based claims, and the use of imagery/labels. Companies should tighten claims review processes, keep evidence files current, and ensure point-of-sale clarity. Appropriate software tools are crucial to help businesses operationalize the GCC across product copy, packaging and digital forms.
Resources
Green Claims Code – Main guidance (full text).
Green Claims Code checklist - (quick, non-expert explainer).
CMA case page (fashion investigation: ASOS, Boohoo, George at Asda).
Green Claims Code campaign site (overview and quiz).
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