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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.

Start with the messageRequirements and evidence

Module 01 / 04

Audience

Identify who sees the claim and in what context.

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.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Accuracy and clarityExact wording and likely audience understandingIs the claim truthful and unambiguous?
Relevant informationQualifications and omitted limitationsWould the missing context change the impression?
Fair comparisonBaseline, scope and comparison periodAre like-for-like features being compared meaningfully?
Life cycle and supportEvidence boundary and substantiationDoes 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”.

Match the evidence boundaryRequirements and evidence

Module 01 / 04

Change

Identify the packaging modification actually measured.

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.

Original fictional communication review, not approved advertising wording.
Evidence questionRecord to inspectDecision supported
Box material recordCurrent and earlier specificationsWhat changed in the packaging itself
Comparison basisSame functional product and relevant periodWhether the comparison is meaningful
Supplier assertionSource, method and actual coverageWhat the supplier has substantiated
Whole-product headlineOther relevant impacts and limitationsWhether 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.

Challenge the sourceRequirements and evidence

Module 01 / 04

Origin

Identify who first made the assertion.

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.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
ComparatorNamed earlier design or alternativeWhether the baseline is identifiable
FunctionRelevant product purpose and performanceWhether materially different products are compared
MeasurementMethod, inputs and assessed boundaryWhat result the evidence actually establishes
QualificationLimits, conditions and placementWhether 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.

Separate guidance and lawRequirements and evidence

Module 01 / 04

Guidance

Identify the principle relevant to the communication.

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.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Fashion investigationFormal agreements recorded on the case pageDo not describe the agreements as a fine
FMCG investigationClosure without a view on complianceDo not describe closure as clearance
New statutory powersThe operative Act and commencementDo not infer a particular case outcome
Supplier responsibilityCurrent supply-chain guidanceDo 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.

Identify the contextRequirements and evidence

Module 01 / 04

Consumer claim

Consider the CMA consumer-law context.

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.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Actual communicationHeadline, imagery and surrounding wordsWhat the audience is likely to understand
Supporting evidenceSource records and assessment boundariesWhether the exact impression is substantiated
Relevant limitsConditions and missing informationWhether qualifications are clear enough
Final decisionApproved wording and outstanding issuesWhat 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.

Retain the claim basisRequirements and evidence

Module 01 / 04

Message

Exact text and publication context.

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.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Material supplier changesReplacement specification and sourceWhether the advertised feature remains supported
Comparison year changesNew baseline and measurementWhether the comparison still means the same thing
Assessment boundary changesIncluded and excluded stagesWhether the headline now overstates the result
New limitation identifiedUpdated review and wordingWhether 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.

Release the accepted claimRequirements and evidence

Module 01 / 04

Version

Match the final artwork and words.

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.

  1. 101

    Identify the message

    Capture text, image, audience and context.
  2. 202

    Define the impression

    Record what readers are likely to understand.
  3. 303

    Locate the evidence

    Obtain the actual sources behind the assertion.
  4. 404

    Check the boundary

    Match product, period and life-cycle scope.
  5. 505

    Test comparisons

    Review the comparator and meaningful differences.
  6. 606

    Expose limitations

    Assess relevant omissions and qualifications.
  7. 707

    Approve the version

    Review the actual communication for release.
  8. 808

    Monitor changes

    Flag altered products, inputs or evidence.
  9. 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.

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