The Green Claims Code

This week the UK’s CMA (Competition and Markets Authority) released its guidance on environmental claims on goods and services. It’s a corker.

An alternative title could be: “If you greenwash, we’re coming to get you. And we’ve covered every base”.

If you’re not in the UK – it’s still relevant. It’s a blueprint – spread the word so that we can crack down on greenwashing globally. It’s also a brilliant guide for how ethical businesses can communicate in a way that helps our customers to make informed decisions AND shine a spotlight on those who don’t follow the same transparent, specific and clear messaging. It provides a useful framework for reviewing what we offer; what we know about our products; and what we say about ourselves.

If you are in the UK, or you trade in the UK: this is IMPORTANT. 

Following the guidance is good for our customers, so it’s worth taking on board for that reason alone. But the CMA aren’t messing about. From January 2022 they are going to be cracking down on greenwashing. Unless ethical businesses up our game, we will get caught up in that. And it could get messy.

A practical, how-to guide

This article is an in-depth guide to what ethical businesses need to know about the Green Claims Code. It’s not legal advice – but hopefully it’s a clear, practical ‘how-to’ for what we all need to do to comply.

Why the Code is so important

What’s really exciting about the code is the implications for the unethical, cynical greenwashing that is so prevalent.

Could it be that these new guidelines leave no wriggle room for those who claim to produce carbon neutral oil? Or those who make grandiose, aspirational claims about becoming Net Zero (only in the small print explaining this relates to their scope 1 emissions only?)


The full guidelines are cracking – the document covers a LOT of bases. And it’s clear that the CMA is ready to use its might. This isn’t a quick PR stunt. There’s a lot of thinking and input gone into the document, and it looks like there’s an equally well thought-out plan to make sure it’s taken seriously and implemented.

Happy days.

Are unsustainable business models under threat? 

This week, Primark launched a ‘Primark Cares education zone’ – an in-store display of what it’s doing to become more sustainable.

Of course, it’s one thing to make sure claims are accurate, but that doesn’t help if a business is operating a fundamentally unsustainable business model.

Or does it?

One of the crucial things about the CMA guidelines is that there’s a heavy focus on not omitting relevant information; and ensuring that the full life cycle of products is taken into account.

There is even reference to the role of durability and disposability in environmental impact. Fast fashion: you’re on notice.

Clearly, unsustainable business models won’t be eradicated the moment the CMA starts tackling greenwashing. But it’s going to be much harder for businesses to present a glossy aura of “We care” whilst continuing to operate in a fundamentally unsustainable way. 

It’s a lot harder to make “Our clothes will be made of recycled fibres” sound good when you have to accompany that with “but they’ll release microfibres into the ocean and are extremely hard to recycle”.

It’s not so much that these companies are being forced to change what they do. But they will have to stop presenting half the picture.

Not being able to make claims that miss out information that customers would want to know? Not getting away with presenting half a story? Surely that’s going to be one of the most effective ways of ‘encouraging’ meaningful changes in unsustainable practices.

Imagine a world… 

Section 3.50 from the guidelines says:

“Claims about a business’s environmental ambitions must also be in proportion to its actual efforts. They are less likely to be misleading when they are based on specific, shorter term and measurable commitments the business is actively working towards. Where any benefits or impact would accrue over a longer period, that would need to be made clear, as there is more risk of consumers being misled if that benefit or impact is not immediate.” 

If only the CMA regulated governments…

If you do have any questions about the guidance, please do drop me an email – I can’t promise to know the answer (and “anything I say isn’t legal advice”!) but hopefully I’ll know someone who does.

Photo by Brian Yurasits on Unsplash

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