The Green Claims Code: part two - the checklist

We're back with the second part of our short series on the Green Claims Code, the guidelines set up by the Competition and Markets Authority (CMA) that UK companies must follow if they want to say they're better for the environment. 

In our last post we covered the background and intention of the code, and what can happen to companies caught breaching the rules and greenwashing. Today we're going to look at the rules in more detail. What is the Green Claims Code checklist, and what are some practical examples of its principles? 

Get those clipboards out and let's get marking! 

What should a green claim look like?

Claims that are compliant with the Green Claims Code will follow six principles. These are:

1. Claims must be truthful and accurate

A green claim should only give the impression that a product or process is as beneficial as it really is, and they shouldn’t over-emphasise a single detail of their products or processes while ignoring other parts that might just as important to overall environmental impact.

The CMA gives the example of a pair of jeans simply labelled “organic cotton”, when organic cotton only makes up 35% of the material used to make the jeans. 

Anyone reading the label would probably assume that the jeans were 100% organic cotton, so the label is likely to be misleading. It would be better if it said “these jeans are manufactured from 35% organic cotton” and the other materials used were listed as well.

A lightbulb

2. Claims must be clear and unambiguous

The meaning of a claim should not just be truthful, it should be obvious to everyone; not confusing or vague. Businesses who are making green or environmental claims should ask themselves; “is the meaning of the terms used clear to customers?” 

Let’s say a business is making light bulbs packaged in cardboard boxes. The boxes are marked simply “recyclable”. Does “recycleable” refer to just the box itself, or the light bulb as well? It’s not clear, so the claim needs to be more specific - it should say “recyclable packaging” instead. 

Labels on jeans

3. Claims must not omit or hide information

Claims “must not omit or hide information that consumers need to make informed choices.” Would a customer who bought a product on the basis of a specific claim be disappointed to learn additional information that hadn’t been included? If so the claim should be removed, or the company should think about how this additional information could be added in. 

But what if there isn’t enough space to include all of the relevant information? In the case of the company making jeans using partly organic cotton, what if they don’t have space to put all of their materials and “35% organic cotton” on their label? 

It might be possible to publish the information elsewhere, like on the company website, and include a clear link to this information in the form of a QR code or website address next to the claim. This is difficult for our jeans manufacturer; it’s tricky to include a QR code on a fabric label! But if the company can’t include the information needed to clarify a claim on their label, they shouldn’t use the label to make that claim.

electric car charging

4. Comparisons Need to be Fair and Meaningful

If a business wants to make comparisons with other products or companies they must  compare like-with-like, on the basis of transparent, accurate evidence that potential customers can freely access. 

A company manufacturing hybrid cars, for example, shouldn’t compare the CO2e emissions from their vehicles with the CO2e emissions from a company that makes diesel trucks. A more reasonable comparison would be with another hybrid car manufacturer, or a company that makes similar kinds of passenger cars that use standard fuel. 

The comparison also needs to have evidence to back it up, so our car manufacturer would need evidence of their emissions and the equivalent emissions of the comparison companies, and this evidence should be published so customers can judge for themselves. 

If you’ve visited our green credentials page you’ll see that we’re following this principle ourselves. We know that if our customers weren’t coming to us for sustainable toilet rolls and tissue products they’d be going to another top UK brand, or another eco manufacturer. So that’s who we compare to, with direct comparisons based on all of the published information we can find. 

Docks with boats and many shipping containers

5. In making the claim you must consider the full life cycle of the product or service

Businesses making green claims, should consider the whole life cycle of the product and the materials it’s made out of, and how all of this is transported and disposed of. 

The CMA gives an example of a company that makes its operations more energy efficient, and publishes the claim that it has a “33% lower carbon impact”. This is true of the manufacturing stage of their products, but their transport is unchanged, and this is actually where most of its emissions come from, so the overall decrease in their overall climate footprint is much smaller than 33%.

A customer would want to know this, so the claim should be updated to make it clear they are only talking about one part of their footprint, and all of the figures the company has about its carbon impact - not just that one reduction - should be available.

For an example you can check out our own Naked Sprout LCA, which has the CO2e emissions of the different stages of our raw material supply, transport, and manufacturing clearly laid out. 

a hand holding a toilet roll

6. Claims must be substantiated

As we noted in part one, green claims are generally objective, measurable facts about environmental benefits.

So it stands to reason that businesses should hold up to date evidence that supports the claims made. The more broad a claim is, the more robust the evidence needs to be. If a company wants to say they are selling “the UK's most sustainable toilet rolls,” for example they need to have great evidence about their own environmental impact on a variety of measures that customers would expect to be included under the banner “sustainable,” and this evidence needs to be easily accessible, wherever the claim is made. 

This is a challenging one - but we’re doing it! We proudly state that Naked Sprout makes the most sustainable toilet rolls in the UK. It’s a bold claim, and backing it up requires a lot of evidence about every part of our operations and those of our competitors, all of which you can see clearly laid out on our green credentials page.

various reading devices on a desk


The CMA Guidance on green claims is a hefty document at 56 pages of rules and examples, but having applied its principles ourselves, they boil down to simple transparency. 

The Code encourages businesses to ask themselves “do we live up to the claims we are making?” If they cannot answer with a resounding yes, they shouldn’t be making the claim! Or, better yet, they should be taking steps to improve their processes, their products, and their evidence base, so that they can be loud and proud about how they’re improving. 

And for customers, the Code provides a useful lens to judge genuine progress from greenwash. Next time you see a company describe itself as “eco-friendly” you can ask yourself; do you understand what this company means by this, what part of their processes or products they’re talking about, and what they’re leaving out? Have they provided enough information so you can judge for yourself?

If not, let them know, and if there’s ever anything you’re unsure about with Naked Sprout - please ask! 

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