The CMA Green Claims Code is changing how organisations communicate their environmental performance.
For years, businesses have used terms such as “sustainable”, “environmentally friendly” and “good for the planet” to describe their products, services and operations. However, growing regulatory scrutiny means that broad environmental statements are no longer enough.
Companies must now demonstrate what their claims mean, what evidence supports them and whether important information has been omitted.
This is an important step in reducing greenwashing and protecting consumers. However, it is also creating another, less visible consequence.
Some organisations are becoming reluctant to communicate genuine sustainability progress because they are unsure whether their environmental claims will withstand regulatory scrutiny.
This growing silence is commonly known as greenhushing.
What Is the CMA Green Claims Code?
The Competition and Markets Authority is the United Kingdom’s primary competition and consumer authority.
The CMA introduced the Green Claims Code to help businesses understand their responsibilities under consumer protection law when making environmental claims about products and services. The guidance applies across the economy and includes written statements, advertisements, websites, product packaging, symbols, graphics, colours and environmental branding.
An environmental claim may suggest that a product, service, brand or business:
Uses fewer natural resources
Produces fewer emissions
Contains recycled materials
Creates less waste
Is more energy efficient
Has a lower environmental impact than an alternative
These claims can help consumers make more informed decisions. They can also allow organisations that have invested in genuine environmental improvements to communicate those achievements.
However, the information must be accurate, clear and capable of being substantiated.
Why the CMA Green Claims Code Matters More Today
Environmental communication is no longer only a marketing consideration.
It is also a consumer protection and compliance issue.
The Digital Markets, Competition and Consumers Act 2024 introduced stronger consumer protection enforcement powers. These changes came into force in April 2025.
The CMA can now determine whether consumer protection law has been infringed, issue directions, require consumer redress and impose financial penalties without first taking a business through the traditional court process. Businesses that breach consumer protection law can face penalties of up to 10 per cent of their worldwide turnover.
This significantly increases the potential consequences of making unsupported or misleading environmental claims.
As a result, sustainability communication must be treated with the same level of governance as financial, legal and regulatory communication.
From Greenwashing to Greenhushing
Greenwashing occurs when environmental communication creates a misleading, exaggerated or incomplete impression of the environmental performance of a product, service or organisation.
This does not always involve an intentionally false statement.
A claim can become misleading because it:
Uses vague language
Excludes important information
Focuses on one positive feature while ignoring a larger environmental impact
Uses a comparison without explaining the basis of that comparison
Relies on outdated or incomplete evidence
Creates an environmental impression through colours, images or symbols that cannot be supported
The increased focus on greenwashing is necessary. Consumers should be able to trust the environmental information presented to them.
However, growing regulatory pressure is also encouraging some organisations to remain silent.
Greenhushing describes a situation in which an organisation reduces or avoids communicating its environmental activities, targets or achievements because it is concerned about criticism, reputational damage or regulatory action.
The organisation may be making genuine progress. It may have reduced energy use, improved waste management, changed suppliers or measured its greenhouse gas emissions.
However, it does not publicise these improvements because it is uncertain about what it can safely say.
Why Organisations Are Becoming More Cautious
Many organisations now ask several questions before publishing an environmental claim.
Can we prove this statement?
Is the language too general?
Does the evidence cover the entire claim?
Are the calculations current?
Have we explained the reporting period and baseline?
Are we presenting the full environmental impact?
Could any important information be missing?
Does the evidence come from a reliable source?
When these questions cannot be answered confidently, the safest decision may appear to be saying nothing.
This hesitation does not necessarily mean that organisations are failing to take environmental action.
In many cases, the problem is that they cannot translate their technical sustainability information into language that is clear, understandable and legally defensible.
What the CMA Green Claims Code Expects
The CMA Green Claims Code establishes six important principles for environmental claims.
1. Claims must be truthful and accurate
An environmental statement should accurately describe the product, service or activity being promoted.
The wording should not exaggerate the environmental benefit or create an impression that is broader than the available evidence.
2. Claims must be clear and unambiguous
Consumers should be able to understand exactly what the environmental statement means.
Terms such as “green”, “sustainable” and “environmentally friendly” can be difficult to interpret when they are presented without an explanation.
Businesses should define what part of the product, service or organisation the claim covers.
3. Important information must not be hidden
A statement can be technically accurate but still misleading if important information is excluded.
For example, a company should not promote a reduction in packaging while failing to explain that the overall environmental impact of the product has increased.
4. Comparisons must be fair and meaningful
Environmental comparisons should use equivalent products, consistent calculation methods and appropriate reporting periods.
A company should clearly explain what it is comparing and how the result was calculated.
5. The full life cycle should be considered
Organisations should consider the complete environmental impact of a product or service.
This may include:
Raw material extraction
Manufacturing
Transportation
Product use
Maintenance
Waste treatment
Recycling
Final disposal
A claim based on only one stage of the life cycle may create a misleading overall impression.
6. Claims must be supported by evidence
Businesses should hold robust, credible, relevant and current evidence before making an environmental claim.
The type of evidence required will depend on the nature of the statement. It may include emissions calculations, energy records, supplier information, waste documentation, product testing, certification or life cycle assessment results.
These principles form the foundation of the CMA Green Claims Code.
Sustainability Communication Is Moving from Storytelling to Proof
In the past, sustainability communication often relied on broad and persuasive language.
Common statements included:
“Eco friendly”
“Better for the planet”
“Produced sustainably”
“Made with green materials”
“Environmentally responsible”
These phrases may sound positive, but they provide very little information about what has actually been measured or improved.
Under the current approach, organisations need to explain:
What has changed
What the claim applies to
How the environmental benefit was calculated
Which baseline was used
What reporting period is covered
What evidence supports the statement
What limitations apply to the result
This represents a fundamental shift in sustainability communication.
Organisations are moving from telling environmental stories to presenting evidence based environmental claims.
The Real Challenge Is Translation, Not Intention
Most organisations are not deliberately attempting to mislead customers.
The more common problem is a gap between technical sustainability data and public communication.
A company may already have:
A greenhouse gas inventory
Electricity and fuel records
Waste transfer documentation
Supplier questionnaires
Product emissions calculations
Environmental certifications
Reduction targets
Operational improvement records
However, this information may be held across different departments, spreadsheets, systems and suppliers.
Marketing teams may not understand the calculation methodology.
Sustainability teams may not know how to communicate technical results in language that customers can easily understand.
Senior decision makers may not know whether the available evidence is strong enough to support a public claim.
The main challenge is therefore not always intention.
It is translation.
Organisations need a process that converts complex sustainability information into claims that are clear, measurable, proportionate and supportable.
Responsibility Extends Across the Supply Chain
Environmental claims are rarely created using information from only one organisation.
A retailer may receive environmental information from a manufacturer. The manufacturer may rely on data from material suppliers, logistics providers, testing laboratories and certification bodies.
In January 2026, the CMA published additional guidance explaining how responsibility for environmental claims operates across supply chains.
The guidance makes clear that retailers, brands, manufacturers and other participating businesses all have a role in ensuring that environmental claims are accurate and not misleading. Passing information from another organisation to a consumer does not automatically remove responsibility.
Businesses may therefore need to verify:
Where the information originated
How the data was calculated
Whether the methodology is appropriate
Whether the evidence is current
Whether the claim has been independently tested
Whether the supplier can provide supporting documentation
Whether the information has changed since it was first provided
Where sufficient evidence cannot be obtained, an organisation may need to change the wording of the claim, limit its scope or avoid making it.
This makes supplier data quality an essential part of sustainability communication.
How Businesses Can Communicate Environmental Progress Safely
Organisations should not respond to regulatory scrutiny by abandoning sustainability communication altogether.
Instead, they should develop stronger internal processes.
Start with the evidence
The environmental claim should be developed from the available evidence.
Businesses should not create a strong marketing statement first and then attempt to find information that supports it.
Define the scope clearly
The claim should explain whether it relates to:
A particular product
A product component
A service
A manufacturing site
A reporting period
A business operation
The entire organisation
A statement about one product should not create the impression that the whole organisation has achieved the same environmental performance.
Use measurable information
Where possible, replace broad language with specific results.
Instead of saying:
“Our packaging is better for the environment.”
A company could say:
“We reduced the weight of plastic packaging used for this product by 20 per cent between 2024 and 2025.”
The second statement is clearer because it identifies the material, product, measurement, percentage and reporting period.
Explain the baseline
A percentage reduction has limited meaning without a starting point.
Organisations should explain:
The baseline year
The original value
The current value
The calculation boundary
Any important changes in the business
This allows customers and stakeholders to interpret the result correctly.
Maintain an evidence record
Every important environmental claim should be connected to supporting documentation.
This may include:
Calculation files
Supplier evidence
Invoices
Meter readings
Methodology notes
Certification documents
Independent verification
Assumptions
Data limitations
Approval records
The evidence should be reviewed when the claim is updated or reused.
Establish an approval process
Environmental claims should be reviewed before publication.
Depending on the size of the organisation, this may involve sustainability, legal, compliance, procurement, operations and marketing teams.
The review should confirm that the claim is accurate, understandable, proportionate and supported by suitable evidence.
Review claims regularly
Environmental information can become outdated.
Supplier arrangements change. Emission factors are updated. Products are redesigned. Packaging materials change. Business activities expand or contract.
Claims should therefore be reviewed periodically to ensure that they remain accurate.
The Competitive Advantage Is Moving from Visibility to Credibility
The companies that succeed in this environment may not be those making the boldest environmental statements.
They will be the organisations that can explain their progress clearly and prove what they say.
Credible sustainability communication can help businesses:
Build customer confidence
Strengthen supplier relationships
Respond to procurement requirements
Prepare for regulatory scrutiny
Demonstrate progress to investors
Differentiate products and services
Reduce reputational risk
Support environmental reporting
The value of a sustainability claim will increasingly depend on the quality of the evidence behind it.
Visibility may attract attention.
Credibility builds trust.
Final Thoughts
The most significant impact of the CMA Green Claims Code is not simply that it is discouraging greenwashing.
It is changing the language of sustainability.
Broad promises are being replaced by defined statements.
Marketing language is being supported by technical evidence.
Supplier claims are being examined more carefully.
Environmental communication is becoming a structured governance process.
For some organisations, this creates hesitation and increases the risk of greenhushing.
For others, it creates an opportunity to lead.
Businesses that can measure their environmental performance, maintain credible evidence and communicate their results with precision will be better positioned to earn trust.
The future of sustainability communication will not be determined by who makes the biggest claim.
It will be determined by who can support it.
How SustainZone Can Help
SustainZone helps organisations convert sustainability information into clear, measurable and credible communication.
Our support can include carbon footprint measurement, supplier data collection, emissions analysis, evidence preparation, environmental reporting and the development of defensible sustainability statements.
By connecting technical sustainability data with clear communication, businesses can demonstrate genuine environmental progress without relying on vague or exaggerated claims.
Speak to SustainZone about developing clear, evidence based and credible sustainability communication for your organisation.
This article provides general information and should not be treated as legal advice. Businesses remain responsible for understanding and complying with the laws and regulations that apply to their environmental claims.
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