Green Claims That Stand Up: CMA Rules for E-Commerce Messaging

Green claims now carry real financial risk

For years, the worst realistic outcome of a shaky 'eco-friendly' label was an Advertising Standards Authority ruling and an awkward press cycle. That changed with the Digital Markets, Competition and Consumers Act 2024. Since April 2025 the Competition and Markets Authority (CMA) has been able to enforce consumer protection law directly, without taking a business to court first, and it can fine companies up to 10% of global turnover for breaches. Misleading environmental claims sit firmly on its stated priority list.

Small brands are not below the radar. The CMA's investigation into fashion retail ended in 2024 with public undertakings from ASOS, Boohoo and George at Asda, followed by compliance guidance the whole sector is expected to follow. And 'claims' means far more than the sustainability page you wrote once and forgot: product descriptions, packaging artwork, category names, paid ads, email subject lines and social captions all count in the regulator's eyes.

What the Green Claims Code actually asks

The CMA's Green Claims Code, first published in 2021, rests on six principles. None of them ban green marketing. They ban vagueness.

• Be truthful and accurate: the claim must be literally correct and give an accurate overall impression of the product.
• Be clear and unambiguous: a reasonable customer should take away the meaning you intended, not a rosier one.
• Do not omit or hide important information: if only the box is recycled and the product inside is not, say so.
• Make fair and meaningful comparisons: compare like with like, using the same measure over the same period.
• Consider the full life cycle: a claim about materials cannot quietly ignore manufacturing, transport or disposal.
• Substantiate everything: hold robust, up-to-date evidence before the claim goes live, not after a complaint arrives.

Note that the Code covers implied claims too. Leafy imagery, earthy colour palettes and brand names with 'eco' or 'green' in them create an environmental impression that needs exactly the same evidence as written copy.

Risky claims, rewritten

The fix is nearly always the same move: swap a broad virtue word for a narrow, checkable fact about your own product. Some worked examples of the pattern:

• 'Eco-friendly packaging' becomes 'Shipped in an FSC-certified cardboard box sealed with paper tape; recycle it kerbside.' Specific, checkable, complete.
• '100% recyclable' becomes component-level honesty: 'Bottle and cap recyclable kerbside; pump not currently recyclable, please remove it first.' The UK's OPRL labelling scheme exists precisely because blanket claims mislead.
• 'Biodegradable' becomes 'Certified industrially compostable to EN 13432; not suitable for home composting.' Unqualified biodegradability claims are a classic enforcement target, because most materials only break down under specific conditions that a landfill does not provide.
• 'Carbon neutral' is best retired if it rests solely on purchased offsets; the ASA has upheld complaints against unqualified neutrality claims. Describe what you have actually measured and changed instead: the courier switch, the consolidated shipping, the removed plastic.
• 'Sustainable' as a standalone descriptor is close to impossible to substantiate. Name the attribute doing the work: organic cotton, a stated recycled-content percentage, a refill scheme, a repair service.

What counts as evidence

Substantiation means documents you could hand to a case officer tomorrow, dated before the claim went live. For a small e-commerce business that is an evidence file per claim, not a consultancy project. Each file should contain:

• Supplier certificates (FSC, GOTS, OEKO-TEX, Soil Association and the like) with scope and expiry dates checked
• Test reports or standard certifications behind any recyclability or compostability claim
• The calculation behind any percentage you quote, such as recycled content
• The date the claim was published and the date the evidence was last reviewed
• The name of the person who signed it off

Two cautions. First, third-party certification beats a supplier's covering letter, so chase the actual certificate rather than accepting an email that says 'it's all recycled'. Second, avoid designing your own green badges or tick-mark roundels; the CMA has warned that home-made labels which look like independent certification are themselves misleading.

The places claims hide

Most businesses audit the main product page and stop. Trouble tends to start in the corners nobody rechecks:

• Category filters and edits: a 'sustainable edit' or 'conscious collection' needs published criteria for what qualifies, a point the CMA made explicitly in its fashion guidance
• Packaging artwork approved two suppliers ago, still carrying a claim that is no longer true
• Marketplace listings on Amazon, Etsy or eBay written in a hurry and never reviewed
• Influencer briefs: if a creator repeats your exaggeration, that is your claim too
• Comparison tables against competitors, where 'greener than' needs a fair, like-for-like basis
• Customer service macros and FAQ answers that promise more than the product page does

A one-afternoon compliance audit

You can get most of the way to compliance in a single working session. Work through it in this order:

• 1. Export every environmental claim: product pages, packaging files, ads, emails, social bios, marketplace listings.
• 2. Sort each claim into 'specific and evidenced', 'specific but unevidenced' and 'vague'.
• 3. For unevidenced claims, request the certificate or test report from your supplier this week; unpublish the claim until it arrives.
• 4. Rewrite every vague claim using the pattern above, or delete it.
• 5. Check imagery and badges for implied claims, and remove any self-invented certification marks.
• 6. Create the evidence file and diarise a six-monthly review, because certificates expire and supply chains change.
• 7. Brief anyone who writes for the brand, including freelancers and agencies, on the six principles.

Done properly, this is not a marketing haircut. Specific claims convert better than vague ones because they read as true. If you would like a second pair of eyes on your product copy and claims file, our copywriting and e-commerce teams can run this review with you.