Environmental claims assessment: how in-house teams review green claims before publication

An environmental claims assessment is the review an in-house team runs on each green claim before it is published: what the wording tells a customer, whether the evidence supports all of it, and which rules apply in each market. This guide sets out how marketing, sustainability and legal teams can do that themselves, with the rules as they stand in October 2026.

What counts as an environmental claim

Any statement, image or name that suggests a product, service or business is better for the environment, or less harmful, is an environmental claim. That includes broad words such as eco-friendly, sustainable and green; specific ones such as made with 30% recycled plastic, recyclable and carbon neutral; and impressions created by leaves, globes and the colour green next to a product.

Claims about a company's future targets count too. So do comparisons such as lower emissions than our previous model.

The rules an environmental claims assessment checks against

UK: the CMA Green Claims Code. Published by the CMA in September 2021, it sets six principles: claims must be truthful and accurate; clear and unambiguous; must not omit or hide important information; must make fair and meaningful comparisons; must consider the full life cycle of the product; and must be substantiated.

UK: the DMCC Act 2024. Since April 2025 the CMA can enforce consumer protection law directly, including against misleading green claims, and fine a business up to 10% of its global turnover or £300,000, whichever is greater.

UK: the CAP Code, section 11. For ads, the basis of an environmental claim must be clear (rule 11.1); absolute claims need a high level of substantiation and comparative claims such as greener need a clear basis (11.3); claims should be based on the full life cycle unless the ad says otherwise (11.4).

EU: Directive (EU) 2024/825. Member states must apply it from 27 September 2026. It bans generic environmental claims, broad claims that don't say clearly what the benefit is, unless the trader can show recognised excellent environmental performance, and bans claiming that a product has a neutral, reduced or positive greenhouse gas impact on the basis of offsetting. UK brands selling into the EU need to check their EU copy.

US: the FTC Green Guides (16 CFR Part 260). They tell marketers not to make unqualified general environmental benefit claims, and give specific guidance on carbon offsets, certifications and seals, recyclable claims and recycled content.

How to run an environmental claims assessment

Environmental claims analysis works claim by claim. For each one, the team answers five questions and writes the answers down.

• What exactly is claimed? Write the wording, plus any image or name that adds to it.
• What will a customer take it to mean? Recyclable packaging is read as the whole pack, recyclable where the customer lives. If only the bottle is, the claim says more than the evidence.
• Which part of the life cycle does it cover? If it covers only manufacture, or only one material, the claim must say so.
• What is it compared with? Any lower, less or better needs a named baseline, a date and a like-for-like measure.
• Which markets and channels? The UK, EU and US rules differ, and packaging, ads and websites can be covered by different rules.

The evidence each kind of green claim needs

The evidence must support the whole impression, for the product as sold. As a starting point:

• Recycled content: supplier certificates or chain-of-custody records showing the percentage, for the material and period claimed.
• Recyclable: proof the whole item, or the named part, can be collected and recycled in practice where it is sold.
• Carbon and emissions: the calculation, its method, the scope covered, the baseline and the period, ideally checked by a third party.
• Carbon neutral or net zero: for EU copy, claims based on offsetting are banned under Directive 2024/825; elsewhere, show the reductions made and the offsets used, separately.
• Compostable: the standard it meets, whether that is home or industrial composting, and every component it covers.
• Certifications and labels: the certificate, what it covers, who issued it and when it expires.
• Broad words such as sustainable: these need the strongest evidence of all, across the full life cycle, and are usually better replaced by the specific benefit.

Where green claims have gone wrong

In January 2022 the ASA upheld four of five issues against Oatly, including a claim of 73% less CO2e vs. milk, because the evidence covered one product against whole milk only. In February 2022 it upheld a complaint against Innocent's TV ads, which implied that buying its products was a choice with a positive environmental impact.

In March 2024 ASOS, Boohoo and Asda gave the CMA formal undertakings to make their green claims specific, including the fabric content behind them, without admitting wrongdoing. In the US, in April 2022, Kohl's and Walmart agreed to pay $2.5 million and $3 million over textiles marketed as bamboo that were rayon.

Qualifying broad sustainability wording

If the evidence is narrower than the claim, change the claim. Replace the broad word with the specific benefit, name the part of the product it covers, give the baseline and the date for comparisons, and keep any condition next to the claim rather than in a footnote.

Pre-launch checklist

Use this for each green claim before it goes out. It is a working checklist, not legal advice.

For a first pass on a page of copy, check environmental wording with the free claim checker. To see how Veridat keeps green claims with their evidence and sign-off, read the sustainability use case.

• Every environmental claim is listed, including images, icons and product names.
• The likely customer reading of each claim is written down.
• The evidence covers the full life cycle, or the claim says which part it covers.
• Comparisons name the baseline, the date and the measure.
• Broad words are replaced by the specific benefit, or backed by evidence for all of it.
• Offset-based neutral claims are removed from EU copy.
• The UK, EU and US rules have been checked for each market the claim runs in.
• A reviewer has approved the wording, with any conditions recorded.
• Each piece of evidence has a review date.

Questions

What is environmental claims assessment?
It is the review an in-house team runs on each green claim before publication: what the wording tells customers, whether the evidence supports all of it for the product as sold, which rules apply in each market, and who approved the final wording. It ends with a recorded decision and a date to review the evidence.

What is environmental claims analysis?
It is the claim-by-claim part of the assessment: identifying each environmental statement, image or name, classifying it as recycled content, recyclability, carbon, certification or broad wording, and comparing it with the evidence you hold. It shows which claims need more evidence or narrower wording before anyone signs off.

Do the EU rules apply to UK brands?
They apply to claims made to consumers in EU member states, which apply Directive (EU) 2024/825 from 27 September 2026. A UK brand selling into the EU needs to check that copy against them, in particular broad claims that don't say what the benefit is, and neutral or reduced impact claims that rely on offsetting.

Can product claims become green claims?
Yes. A product claim becomes an environmental claim as soon as it refers to materials, recyclability, energy use, emissions, waste or sourcing, or uses images that suggest an environmental benefit. Those claims need the same assessment as any other green claim, with evidence for the product as sold.

This guide is for information only and is not legal advice. For decisions about specific environmental claims, speak to a qualified adviser.