Standards and reporting
Green Claims Code
A green-claims review asks what the audience will understand, whether that impression is supported and whether material limits are clear where the claim is made.
What is the Green Claims Code?
The Code sets out the CMA’s view of how consumer law applies to environmental claims about goods, services, brands and businesses Green Claims Code, scope and summary.
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Audience
Identify who sees the claim and in what context.
Module 02 / 04
Impression
Read the overall message rather than isolated wording.
Module 03 / 04
Evidence
Find support for that precise message.
Module 04 / 04
Limit
Identify information that would materially change understanding.
Read the detailed guidance and evidence
It is guidance rather than a product approval scheme, and displaying its name does not establish that a particular claim is lawful.
The standards overview helps distinguish an inventory, certificate and public claim, while the product carbon footprint guide addresses a particular measurement task.
How can the six principles become practical review questions?
Use the principles to challenge the actual communication rather than treat them as six icons on a marketing checklist.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Accuracy and clarity | Exact wording and likely audience understanding | Is the claim truthful and unambiguous? |
| Relevant information | Qualifications and omitted limitations | Would the missing context change the impression? |
| Fair comparison | Baseline, scope and comparison period | Are like-for-like features being compared meaningfully? |
| Life cycle and support | Evidence boundary and substantiation | Does the evidence support the message across the relevant life cycle? |
Read the detailed guidance and evidence
The Code separately identifies truthful and accurate claims, clear and unambiguous wording, relevant information, fair comparisons, life-cycle consideration and substantiation Six principles.
Grouping the review questions here does not reduce the six principles or establish a prescribed scoring method.
What can a fictional packaging improvement legitimately support?
Fictional case: Mosswick Homeware reduces material in a product’s box and proposes advertising the whole product as a “lower-impact choice”.
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Change
Identify the packaging modification actually measured.
Module 02 / 04
Baseline
Identify the comparison product or earlier design.
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Boundary
Check whether the evidence concerns packaging or the whole product.
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Wording
Assess what the headline implies beyond that evidence.
Read the detailed guidance and evidence
The procurement record may support a specific packaging comparison without establishing a lower overall environmental impact for the product.
The review should investigate the message customers receive rather than assume a detailed footnote turns a broad headline into a narrow material claim.
The CMA’s supply-chain guidance makes clear that responsibility for claims cannot simply be passed to the business that supplied the original assertion Supply-chain guidance.
Which Mosswick evidence gaps matter?
This original fictional review distinguishes a measured change from a broader unsupported inference.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Box material record | Current and earlier specifications | What changed in the packaging itself |
| Comparison basis | Same functional product and relevant period | Whether the comparison is meaningful |
| Supplier assertion | Source, method and actual coverage | What the supplier has substantiated |
| Whole-product headline | Other relevant impacts and limitations | Whether the proposed impression exceeds the evidence |
Read the detailed guidance and evidence
An environmental-management certificate held by a supplier does not on its own demonstrate a particular product comparison.
The ISO 14001 guide explains the organisational management-system boundary, which should remain distinct from Mosswick’s advertised product claim.
Can a retailer rely on a supplier’s green claim?
A recipient should inspect the substantiation and scope rather than repeat the claim solely because another business wrote it first CMA supply-chain guidance.
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Origin
Identify who first made the assertion.
Module 02 / 04
Support
Obtain the underlying evidence rather than a logo alone.
Module 03 / 04
Coverage
Check product, market, period and limitations.
Module 04 / 04
Reuse
Assess the new communication’s own impression.
Read the detailed guidance and evidence
Mosswick’s supplier describes the box as “recyclable”, but the retailer needs to understand what the evidence concerns and what relevant conditions or qualifications apply.
Changing the presentation or adding the claim beside a product image can alter the overall impression, even when the original supplier wording is reproduced exactly.
The Code’s life-cycle and omission principles help frame this review without creating a universal rule that every claim requires the same type of study Life-cycle and substantiation principles.
What should a comparison file preserve?
The file should let a reviewer understand what is compared and why the result supports the proposed words.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Comparator | Named earlier design or alternative | Whether the baseline is identifiable |
| Function | Relevant product purpose and performance | Whether materially different products are compared |
| Measurement | Method, inputs and assessed boundary | What result the evidence actually establishes |
| Qualification | Limits, conditions and placement | Whether readers can understand the comparison correctly |
Read the detailed guidance and evidence
A percentage or attractive graphic cannot repair a comparison that changes its baseline or assessed scope between the old and new product.
The embodied-carbon guide and product footprint guide address measurement boundaries where those specific assessments are used as evidence.
How does the Code relate to current consumer law?
Read the guidance with the current statutory framework rather than assume the Code itself creates every prohibition or monetary penalty DMCC Act Part 4 SI 2025/272.
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Guidance
Identify the principle relevant to the communication.
Module 02 / 04
Law
Identify the applicable consumer-law provision.
Module 03 / 04
Powers
Distinguish the enforcement mechanism from the guidance.
Module 04 / 04
Case
Read an actual outcome before describing a sanction.
Read the detailed guidance and evidence
The Act gives the CMA monetary-penalty powers under specified conditions, with turnover addressed in a separate provision rather than left as an undefined marketing phrase DMCC Act section 182 DMCC Act section 204.
A reference to potential maximum powers should not be rewritten as a claim that a particular green-claims investigation resulted in a fine.
This guide does not provide a legal opinion on Mosswick’s proposed communication.
How should published CMA cases be described?
Distinguish the recorded outcome from a dramatic but unsupported enforcement headline.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Fashion investigation | Formal agreements recorded on the case page | Do not describe the agreements as a fine |
| FMCG investigation | Closure without a view on compliance | Do not describe closure as clearance |
| New statutory powers | The operative Act and commencement | Do not infer a particular case outcome |
| Supplier responsibility | Current supply-chain guidance | Do not assume copying a claim transfers all responsibility |
Read the detailed guidance and evidence
The fashion case records agreements, while the FMCG case records closure without taking a compliance view, so the two outcomes are not interchangeable CMA fashion case CMA FMCG case.
When are ASA or FCA rules relevant as well?
Identify the communication and regulated context instead of presenting every green claim as governed by one identical enforcement route.
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Consumer claim
Consider the CMA consumer-law context.
Module 02 / 04
Advertisement
Check applicable advertising-code requirements.
Module 03 / 04
Financial service
Check the FCA rule’s actual scope.
Module 04 / 04
Firm claim
Distinguish a business-level claim from a product reference.
Read the detailed guidance and evidence
CAP Code section 11 addresses environmental claims in advertising, while FCA ESG 4.3.1R concerns sustainability references about products and services within its authorised-firm scope CAP Code section 11 ESG 4.3.1R.
The FCA SDR guide explains the separate product naming, labelling and disclosure decisions.
A corporate sustainability report is not automatic permission to reuse every statement as an unqualified consumer advertisement.
What should the approving reviewer receive?
Review the message in its proposed setting rather than approve wording without the image, layout or qualification.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Actual communication | Headline, imagery and surrounding words | What the audience is likely to understand |
| Supporting evidence | Source records and assessment boundaries | Whether the exact impression is substantiated |
| Relevant limits | Conditions and missing information | Whether qualifications are clear enough |
| Final decision | Approved wording and outstanding issues | What can be released and what remains unsupported |
Read the detailed guidance and evidence
Mosswick keeps a rejected broad headline beside the accepted narrower wording so the next campaign does not accidentally revive the unsupported version.
The evidence review should also identify when a supplier specification or product change would require the claim to be reassessed.
What would a useful original claim register contain?
A claim register can connect the public message to its source evidence and expiry triggers without acting as an automated legal-approval machine.
Module 01 / 04
Message
Exact text and publication context.
Module 02 / 04
Evidence
Source, method and assessed population.
Module 03 / 04
Review
Accepted limitations and decision owner.
Module 04 / 04
Trigger
Changes that require reassessment.
Read the detailed guidance and evidence
Mosswick’s planned register separates the packaging-material claim from any whole-product or corporate statement, with a source and reviewer for each.
A software RFP should test whether a new specification flags the communications that rely on the old evidence.
A consultancy brief can commission substantiation review without promising regulator approval.
What happens when the supporting evidence changes?
Revisit the communication when a change affects the claim’s actual basis.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Material supplier changes | Replacement specification and source | Whether the advertised feature remains supported |
| Comparison year changes | New baseline and measurement | Whether the comparison still means the same thing |
| Assessment boundary changes | Included and excluded stages | Whether the headline now overstates the result |
| New limitation identified | Updated review and wording | Whether correction or withdrawal needs consideration |
Read the detailed guidance and evidence
The final control is a reasoned decision about the particular message, rather than a green tick attached permanently to the product.
Retain enough history to explain why a previous claim was revised and what evidence supports the current wording.
What should the launch team check immediately before publication?
Check the released communication against the version and evidence the reviewer actually considered.
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Version
Match the final artwork and words.
Module 02 / 04
Qualification
Check the relevant limitation remains visible.
Module 03 / 04
Access
Check linked support is available as intended.
Module 04 / 04
Owner
Identify who acts when the evidence changes.
Read the detailed guidance and evidence
Mosswick’s final proof review catches the qualifier being removed from the product page while remaining in a separate technical document.
That change needs a new impression assessment rather than administrative sign-off that the sentence was approved in another layout.
The CMA’s clarity and omission principles make the communication context part of the task, not merely the underlying calculation Clarity and relevant-information principles.
How can the team prepare a reviewable evidence file?
This editorial workflow organises preparation without certifying compliance or replacing a statutory process.
- 101
Identify the message
Capture text, image, audience and context. - 202
Define the impression
Record what readers are likely to understand. - 303
Locate the evidence
Obtain the actual sources behind the assertion. - 404
Check the boundary
Match product, period and life-cycle scope. - 505
Test comparisons
Review the comparator and meaningful differences. - 606
Expose limitations
Assess relevant omissions and qualifications. - 707
Approve the version
Review the actual communication for release. - 808
Monitor changes
Flag altered products, inputs or evidence. - 909
Retain the history
Keep accepted wording and reasons for corrections.
Frequently asked
Questions people ask
Is the Green Claims Code itself a law?
It is CMA guidance on consumer law rather than a certification scheme or separate statute.
Does a supplier certificate prove our claim?
No, assess what it actually covers and whether it substantiates your own communication.
Can a packaging improvement support a whole-product claim?
Only if the evidence supports the overall impression, with relevant life-cycle boundaries and limitations considered.
Were the fashion firms fined in the cited case?
The case page records formal agreements, which should not be described as a monetary fine.
Is a closed investigation the same as clearance?
No, the cited FMCG case expressly records no view on compliance.
Is FCA anti-greenwashing the same regime?
No, assess its authorised-firm product/service scope separately from general consumer claims and advertising rules.
Sources
Primary sources
Primary provisions and official owner guidance checked on 26 October 2026; historical and draft resources are labelled in the guide.
- CMAMaking environmental claims on goods and services
- CMAMaking green claims across the supply chain
- CMAFashion greenwashing investigation
- CMAFast Moving Consumer Goods investigation
- UK legislationDigital Markets, Competition and Consumers Act 2024, Part 4
- UK legislationDMCC Act, section 182: monetary penalties
- UK legislationDMCC Act, section 204: turnover
- UK legislationDMCC commencement Regulations 2025
- ASA/CAPCAP Code section 11: environmental claims
- FCAESG 4.3: FCA anti-greenwashing and naming rules