UK Green Claims Compliance: Business Guidance

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Environmental and sustainability claims are increasingly used to communicate responsible business practices. In the UK, these claims are now subject to stronger oversight and enforcement. Regulators are no longer focusing only on what companies intend, but on what they can clearly prove.

For businesses, this means that any statement suggesting environmental benefit must be accurate, specific, and supported by evidence that can be explained to customers, regulators, and investors.

The below guide covers a overview of core aspects to consider when considering your own claims:



1. What Is a “Green Claim”?

A green (or environmental) claim is any statement that suggests a product, service, or business has a positive impact on the environment or causes less harm than alternatives.

This includes:

  • Words like “eco-friendly,” “sustainable,” “green,” “low carbon”
  • Symbols, colours, or labels that imply environmental benefit
  • Statements about carbon neutrality, recycling, or reduced impact
  • Future commitments such as “net zero by 2030”

If a customer could reasonably interpret a message as meaning “this is better for the environment,” it is treated as a green claim.


2. Who Regulates Green Claims in the UK?

Two main regulators are involved, with different but complementary roles: The CMA and The FCA.

The Competition and Markets Authority (CMA)

The CMA protects consumers from misleading business practices. It oversees consumer-facing claims, such as those found on:

  • websites
  • packaging
  • advertisements
  • product descriptions

The Financial Conduct Authority (FCA)

The FCA regulates financial firms and markets. Its focus is on:

  • Sustainability claims made to investors
  • ESG-related marketing of financial products
  • Disclosures by FCA-authorised firms

3. The CMA’s Powers & the Green Claims Code

What Has Changed?

Under recent legislation, the CMA can now:

  • Investigate greenwashing directly
  • Issue fines of up to 10% of global annual turnover
  • Act without first going to court, making enforcement faster

The Green Claims Code Explained

To help businesses comply with legal requirements, the CMA have issued the Green Claims Code. This guidance helps businesses communicate environmental benefits clearly and fairly.

In simple terms, the Code sets expectations for how environmental claims must be made, not just whether they are allowed.

  • Claims must be true and accurate
  • Claims must be clear and specific, not vague
  • Claims must be supported by evidence
  • Claims must consider the full environmental impact, not just one positive feature

Green Claims Code Example

“Environmentally friendly packaging”
“Packaging contains 80% recycled cardboard and is fully recyclable in UK kerbside collections”

Common Types of Claims Under Scrutiny

As a guide, claims such as the below will come under particular scrutiny:

  • Claims using broad terms without explanation (“green”, “planet positive”)
  • Those highlighting one positive feature while ignoring wider impacts
  • Claims relying heavily on carbon offsetting to claim neutrality
  • Comparisons of products to competitors without clear evidence

A Note on Carbon Neutrality Claims

If a business says it is “carbon neutral”, it must be able to show:

  • how emissions were measured,
  • what reductions have actually been achieved,
  • and how offsets are used (if at all).

Offsetting alone is increasingly seen as insufficient without real planning and consideration of emissions reductions.


4. FCA Rules on Sustainability and Greenwashing

The Anti-Greenwashing Rule (In Force Since May 2024)

All FCA-authorised firms must ensure that sustainability-related claims are:

  • Fair (not overstated)
  • Clear (easy to understand)
  • Not misleading

This applies to websites, fund descriptions, reports, and marketing materials.

Anti-Greenwashing Rule Example

Calling a fund “low carbon” requires evidence that emissions are genuinely lower than comparable investments — not just expected to be lower in the future.

FCA Regulation of ESG Ratings: What’s Changing

From June 2028, companies that produce ESG ratings will be regulated. This aims to ensure:

  • Rating methods are transparent
  • Conflicts of interest are managed
  • Scores are reliable rather than marketing tools

Businesses using ESG ratings should understand what the score represents, not treat it as a guarantee of sustainability.


5. What Businesses Should Do Now

Step 1: Identify All Sustainability-Linked Communications

Systematically review all places where environmental benefits are mentioned, including:

  • Websites and product pages
  • Packaging and labels
  • Social media content
  • Marketing campaigns
  • Investor and partner materials

Why this matters

Green claims often accumulate over time across teams and platforms. Language that once felt harmless or aspirational may now create legal or reputational risk. A full review helps businesses:

  • identify inconsistent or outdated claims,
  • avoid accidental overstatement,
  • ensure messaging aligns with actual performance.

This step also provides clarity on where sustainability messaging is genuinely adding value versus where it may be confusing or misleading.

Step 2: Answer 3 Simple Questions

For every green claim identified, write down:

What exactly are we claiming?

What evidence do we have to support it?

Could a customer misunderstand or overestimate the benefit?

Why this matters

Many claims become risky not because they are false, but because they are too broad or undefined. Regulators assess claims based on how an average customer is likely to interpret them.

If your answers are unclear, the claim could be high risk.

Step 3: Verify the Evidence Behind Each Claim

Confirm that each claim is supported by evidence that is:

  • relevant to the claim,
  • current and accurate,
  • proportionate to the strength of the language used.

Why this matters

Under current enforcement expectations, evidence must exist before a claim is made, not in response to a challenge. Weak or unavailable evidence increases exposure to enforcement action and undermines credibility.

Additionally, having evidence readily available:

  • speeds up responses to regulator or customer queries,
  • strengthens internal confidence in sustainability messaging,
  • helps marketing teams communicate responsibly without overreach.

6. Why Green Compliance is an Opportunity, Not Just a Risk

It’s easy to read new rules like these and see only restrictions. But in practice, they’re doing something helpful: they’re raising the standard for everyone.

For years, businesses that invested time and money into genuine sustainability improvements have been competing with vague claims and glossy language that didn’t always reflect real action. Clearer rules help cut through that noise.

When environmental claims have to be specific and evidence-based, it becomes much easier for customers to understand what a business is actually doing; and to trust it.

This also shifts the focus internally. Instead of asking “How green can we say this is?”, teams start asking “What can we confidently explain and stand behind?” That’s a healthier question, and it often leads to better decisions.

Many organisations find that once they step back from broad claims, their sustainability story actually improves. Clearer language highlights real progress, even if it feels more modest at first. Over time, that honesty tends to resonate far more than big promises.

In short, these changes reward clarity, consistency, and follow-through. For businesses already taking sustainability seriously, that’s not a disadvantage, it’s a chance to be recognised for it.


Operating in or selling into the EU?

The EU are also tightening regulation of green claims made by businesses, with a new directive known as EmpCo coming into force during 2026.

Head to our EmpCo Compliance Guide for further detail.


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