If your brand makes environmental claims about products or services sold to UK customers, the Green Claims Code applies to you. Enforced by the Competition and Markets Authority (CMA), this code sets out clear, legally-backed rules about what you can — and cannot — say about your environmental credentials. Getting it wrong can mean enforcement action, reputational damage, and significant financial penalties.
In This Article
- What is the UK Green Claims Code?
- Who Does It Apply To?
- The 6 Core Principles
- Penalties for Non-Compliance
- Compliance Checklist
- What to Do Next
Background
What Is the UK Green Claims Code?
The UK Green Claims Code was introduced by the CMA in September 2021 as part of a broader effort to crack down on greenwashing — the practice of making misleading or unsubstantiated environmental claims to attract eco-conscious consumers.
The code draws on existing UK consumer protection law, specifically the Consumer Protection from Unfair Trading Regulations 2008, and provides practical guidance on how businesses must communicate sustainability claims honestly and accurately.
Since its launch, the CMA has conducted several high-profile investigations into major retailers and fashion brands, signalling clearly that enforcement is no longer hypothetical. The regulatory direction of travel is only increasing in severity and scope.
Key Fact
Following a sweep of sustainability claims across the fashion, travel, and grocery sectors, the CMA found that up to 40% of green claims reviewed could be misleading under existing consumer law. This is not a niche compliance concern — it is a mainstream business risk.
Scope
Who Does the Green Claims Code Apply To?
The Green Claims Code applies to any business that makes environmental claims about its products, services, or overall practices to UK consumers. This includes brands selling directly to consumers (D2C), multi-brand retailers carrying third-party products, online marketplaces, and manufacturers whose products are sold in the UK by other retailers.
Critically for multi-brand retailers: if a third-party brand makes a misleading green claim on a product you stock and sell, your business may also be held liable. You cannot outsource your compliance exposure to your suppliers. You are responsible for the claims that appear under your roof, in your marketing materials, and on your website.
The Framework
The 6 Core Principles
The Green Claims Code is built around six core principles. Every environmental claim your business makes must satisfy all six to be compliant.
Claims must reflect the genuine environmental impact of a product. There is no room for exaggeration or misleading impressions.
The meaning of any claim must be clear to a typical consumer. Vague terms like “eco-friendly” or “green” without further explanation are problematic.
Leaving out significant negative environmental information to make an overall claim appear better than it is counts as misleading under the code.
You must hold robust, verifiable evidence for every claim before it goes live. Evidence gathered after the fact does not count.
Any comparison with other products or your own prior performance must be on a like-for-like basis and be genuinely meaningful to consumers.
A claim that focuses on one positive aspect of a product’s lifecycle cannot ignore significant negative impacts at other stages.
Multi-Brand Retailers: Your Exposure is Broader Than You Think
The CMA’s guidance makes clear that if you are a retailer stocking third-party brands, you share responsibility for the environmental claims those brands make on products sold through your channels. A single non-compliant supplier claim can trigger enforcement action against your business — not just theirs.
See How Retailers Are Managing This →Risk & Enforcement
Penalties for Non-Compliance
The CMA has the power to take businesses to court for breaches of consumer protection law, and recent cases have shown they are prepared to use it. In addition to CMA enforcement, Trading Standards can investigate and prosecute businesses locally.
| Consequence | Severity | Notes |
|---|---|---|
| CMA investigation & formal undertaking | High | Business must change all non-compliant claims and comply with binding undertakings |
| Court-ordered compliance | High | If undertakings are not given or breached, CMA can seek court injunctions |
| Consumer redress orders | High | Courts can order consumer compensation, product refunds, or contract unwinding |
| Reputational damage | Medium–High | CMA investigations are typically publicised; media coverage can be severe |
| Trading Standards prosecution | Medium | Can result in unlimited fines under Consumer Protection from Unfair Trading Regulations |
Practical Steps
A Green Claims Compliance Checklist
Use this checklist to carry out an initial self-assessment of your current claims. This is a starting point — not a substitute for a full compliance audit.
Audit all live environmental claims across your website, product pages, packaging, and marketing materials. Catalogue every instance where an environmental claim is made.
Verify substantiation documents exist for every single claim before it goes live. The CMA’s position is clear: evidence must pre-exist the claim, not be gathered in response to a challenge.
Review third-party brand claims if you are a multi-brand retailer. You cannot assume that your suppliers are compliant — you need evidence of their compliance.
Remove vague or unsubstantiated language such as “eco-friendly,” “sustainable,” “natural,” or “green” unless these terms are clearly defined and fully substantiated in context.
Establish a process for ongoing compliance — claims change as products, certifications, and materials evolve. A one-time audit is not sufficient; you need a repeatable, systematic process.
Taking Action
What to Do Next
Understanding the Green Claims Code is the first step. But the real challenge for most retailers and brands is moving from awareness to operational compliance at scale. Manual processes — spreadsheets, email questionnaires, spot checks — are simply not sufficient for the volume and complexity of claims modern retailers manage.
The businesses that are getting ahead of this challenge are those investing in systematic, technology-driven compliance processes that can handle green claims verification at scale, across both own-brand and third-party products, without requiring armies of compliance staff.
The regulatory landscape will only tighten from here. The EU Green Claims Directive, which will eventually influence UK regulation post-Brexit, raises the bar further still. The time to build a robust compliance infrastructure is now, not when an investigation lands at your door.
Need Help Managing Green Claims Compliance at Scale?
Compare Ethics automates the verification of green claims across all your brands — own and third-party — so you can stay compliant without the manual burden.
Talk to a Specialist
