What is the Green Claims Code?

Quick Answer: The Green Claims Code is a set of principles published by the UK's Competition and Markets Authority (CMA) in September 2021 to help businesses make environmental claims that are honest, accurate, and legally compliant. It sets out six criteria that any green claim must meet, and sits within the broader framework of UK consumer protection law. Businesses that make misleading environmental claims risk enforcement action from the CMA or the Advertising Standards Authority (ASA).

What is the Green Claims Code?

The Green Claims Code is guidance issued by the Competition and Markets Authority (CMA) to help UK businesses understand their legal obligations when making environmental claims about their products, services, or operations.

A green claim is any statement, label, or image that suggests a product, service, or business is better for the environment. This includes explicit statements like "made from 100% recycled materials" and implicit signals like green leaf imagery or the word "eco-friendly" on packaging.

The Code does not create new law. It clarifies how existing consumer protection legislation, specifically the Consumer Protection from Unfair Trading Regulations 2008 and the Business Protection from Misleading Marketing Regulations 2008, applies to environmental marketing. Businesses that breach these rules can face CMA investigation, ASA rulings, or civil enforcement action.

The six principles of the Green Claims Code

The Code sets out six criteria that every green claim must satisfy.

1. Be truthful and accurate The claim must reflect the actual environmental performance of the product or business. Overstating benefits, even through vague language like "sustainable" or "green", is likely to mislead.

2. Be clear and unambiguous The meaning of the claim must be immediately obvious to the average consumer. If a claim applies only to part of a product (for example, the outer packaging but not the inner), that must be stated clearly.

3. Not omit important information Businesses must not cherry-pick positive environmental aspects while concealing significant negative ones. A product's full environmental impact, across its life cycle, is relevant context.

4. Make only fair and meaningful comparisons Any comparison with a competitor or a previous version of the product must be like-for-like. Comparisons must be based on the same scope, methodology, and time period.

5. Consider the full life cycle Claims must account for the environmental impact of a product from raw material extraction through to disposal, not just the stage that reflects most favourably on the business.

6. Be substantiated Businesses must support every claim with credible, verifiable evidence. Businesses should be able to produce that evidence if challenged.

Why does the Green Claims Code matter for businesses making carbon claims?

Carbon-related claims face the most scrutiny under the Code. Statements like "carbon neutral", "net zero", or "we've reduced our emissions by 50%" all qualify as explicit environmental claims and must meet all six criteria.

This is where carbon accounting becomes directly relevant. A business cannot credibly claim to have reduced its carbon footprint, achieved net zero, or cut emissions by a specific percentage without a verified, methodology-aligned carbon footprint to reference. Without that baseline, the claim has no substantiation.

The CMA has already taken enforcement action in this area. In 2024, it concluded investigations into ASOS, Boohoo, and George at Asda, finding that their sustainability claims lacked sufficient clarity and could mislead consumers. H&M reached a $3 million settlement in the US following similar allegations about its "Conscious" collection.

For businesses that want to make carbon claims with confidence, the starting point is a full-scope carbon footprint measured against a recognised standard, such as the GHG Protocol. Seedling produces GHG Protocol-aligned footprints covering Scopes 1, 2, and 3, with a clear audit trail of assumptions, data sources, and emissions factors, giving businesses the documented evidence base the Code requires.

How does the Green Claims Code relate to the EU Green Claims Directive?

The UK's Green Claims Code is guidance, not legislation. The EU's proposed Green Claims Directive, introduced by the European Commission in March 2023, goes further: it would require businesses to have an accredited third party independently verify their environmental claims before making them public.

As of mid-2025, the European Commission has paused the EU Directive's legislative process, signalling a possible withdrawal due to concerns about administrative burden on smaller businesses. However, the direction of travel is clear. Scrutiny of environmental claims is increasing across both the UK and EU, and the standard of evidence required to support those claims is rising.

UK businesses that trade in EU markets, or that anticipate tighter domestic regulation, should treat the Green Claims Code as a floor, not a ceiling.

What counts as a misleading green claim?

The Code identifies several patterns that are likely to constitute greenwashing.

• Vague or generic language such as "eco-friendly", "green", or "sustainable" without specific, verifiable evidence to support it
• Selective disclosure that highlights one positive environmental attribute while omitting significant negative impacts elsewhere in the product's life cycle
• Unqualified comparisons that claim a product is "greener" than a competitor without specifying the scope, methodology, or baseline used
• Claims based solely on offsetting where a business claims carbon neutrality through offset purchases without first reducing its own emissions
• Visual greenwashing where imagery (green colours, leaf icons, nature photography) creates an impression of environmental benefit that the product's actual performance does not support

The European Commission's own research found that 53% of green claims in the EU give vague, misleading, or unfounded information, and 40% have no supporting evidence (European Commission, 2021). The UK picture is comparable.

What does compliance with the Green Claims Code look like in practice?

Compliance is not a one-time exercise. It requires businesses to maintain the evidence behind every claim they make, and to update that evidence as their products and operations change.

In practice, this means:

• Measuring your carbon footprint to a recognised standard before making any carbon-related claim
• Documenting the methodology, data sources, and assumptions behind that measurement
• Making claims specific and scoped (for example, "we reduced Scope 1 and 2 emissions by 18% between 2022 and 2024" rather than "we're going green")
• Reviewing claims annually as you refresh your footprint data
• Keeping records that you could produce to the CMA or ASA if a claim is challenged

The businesses most exposed to enforcement risk are those making broad, unqualified claims without a documented evidence base. The businesses best positioned to make credible green claims are those that treat carbon measurement as an ongoing process rather than a one-off project.

As regulatory expectations continue to rise on both sides of the Channel, the gap between businesses with well-documented carbon data and those without it will become increasingly visible.