Green claims are under closer scrutiny from UK regulators. This makes it essential for organisations to understand what they can say, what they must prove, and how to avoid presenting misleading information.
What are green claims, and what is greenwashing?
Green claims are statements that describe how a product, service, or organisation impacts the environment. These claims can influence consumer decisions, guide stakeholders and investors, and shape brand reputation. When accurate, green claims can help audiences understand the sustainability performance of a business. When inaccurate, they become greenwashing.
The term 'greenwashing' was coined by Jay Westerveld in 1986, who noticed that a hotel was emphasising to guests the importance of reusing towels to prevent environmental damage while, simultaneously, the hotel was causing environmental damage by developing land to extend their hotel. Now, the term is widely used to describe the act of inflating or exaggerating an organisation's (or product's) environmental performance in order to improve reputation or public image.
Greenwashing can affect the quality of green claims and can come in many forms. The Seven Sins of Greenwashing were developed by TerraChoice (now acquired by UL Solutions) to help consumers to identify misleading claims.
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- Hidden Trade Off: A product is described as sustainable based on one feature while important negative impacts are ignored.
- No Proof: Claims are presented without accessible or credible evidence.
- Vagueness: Phrases such as “eco friendly’’ or “green’’ are used without detail or context, and often lack a standard or legal definition.
- Irrelevance: A claim is technically true but offers no meaningful value to the consumer. It may be completely irrelevant to the product or represent only a nominal environmental benefit.
- Lesser of Two Evils: A harmful product is framed as the better choice within a harmful category.
- Fibbing: Claims are entirely false.
- Worshipping False Labels: Images or wording create the impression of third-party approval that does not exist.
Not only do these Sins reduce the reliability of green claims, but they expose organisations to reputational harm and legal risk.
What is the law on greenwashing in the UK?
UK consumer protection law already provides a framework for responsible green claims. The Consumer Protection from Unfair Trading Regulations 2008 requires environmental information to be accurate, specific, and supported by evidence. The Competition and Markets Authority (CMA) applies these rules through its Green Claims Code, which sets out six principles that businesses must follow when making environmental statements.
The Advertising Standards Authority (ASA) enforces similar requirements in advertising. Any green claim must be clear, honest, and capable of independent verification. The ASA reviews claims made on a variety of platforms, including websites, packaging, posters, print adverts, broadcast media, and social media.
Significant changes are on the horizon. The Digital Markets, Competition and Consumers Act 2024 gives the CMA direct enforcement powers. The regulator will be able to fine businesses for false or misleading green claims without first taking them to court. This represents a major shift in the regulatory landscape. Organisations will need to tighten their internal controls and ensure that all environmental information is supported by robust evidence.
How is greenwashing enforced and prosecuted in the UK?
Enforcement in the UK is shared across several regulators.
The Financial Conduct Authority (FCA) plays a leading role in the financial sector, regulating investment products, funds, and financial promotions. The FCA’s anti-greenwashing rule requires firms to ensure that any sustainability related information is fair, clear, and not misleading. The regulator reviews ESG strategies, disclosures, websites, and marketing campaigns with a focus on improving transparency and preventing misleading green claims within financial services.
Across the wider economy, the Competition & Markets Authority (CMA) investigates sectors that present systemic greenwashing risks. It can demand evidence, carry out market studies, and take enforcement action.
The Advertising Standards Authority (ASA) deals with individual adverts. It can order amendments, issue warnings, and ban campaigns.
Local Trading Standards may also prosecute serious breaches of consumer protection law.
Where might organisations greenwash (on purpose or by accident)?
Greenwashing does not always result from deliberate dishonesty. Many organisations produce weak green claims due to inadequate evidence or unclear wording. High risk areas include:
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- Advertising and promotional materials.
- ESG and sustainability reports.
- Carbon reporting, particularly where offsets are used.
- Packaging that references biodegradability, compostability, or recyclability.
- Websites and digital product descriptions.
- Social media posts that reference environmental benefits.
Each of these channels requires careful internal review to ensure claims are accurate and supported by reliable evidence.
How can iCOR help organisations to prevent greenwashing?
The expectations for responsible green claims will continue to rise. Regulators are preparing to take a more assertive approach, and businesses that fail to meet evolving requirements could face penalties, investigations, and public scrutiny.
iCOR helps organisations stay ahead of these developments. Our platform provides monthly updates on legislation and regulatory guidance, ensuring that your team always understands the latest rules and expectations. We help you manage evidence and track your environmental legal compliance duties, giving you the knowledge you need to be able to make accurate and defensible green claims across your advertising, reporting, and external communications.
Book a demo here to learn how iCOR can help you to reduce risk, protect your reputation, and build trust with your stakeholders.