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CMA Green Claims

Green Claims Evidence Checklist

Green claims are high-risk because broad environmental wording can create a stronger impression than the evidence supports. UK teams making sustainability, carbon, net zero, recyclable, lower emissions, or eco-friendly claims should be able to show what the claim means, what evidence supports it, and what qualifications are needed.

7 min read · Advisory workflow guidance, not legal advice

Who should use this green claims checklist?

This checklist is for marketing, sustainability, legal, compliance, product, and founder-led teams that publish environmental claims in the UK. It is relevant to websites, product pages, packaging-style copy, investor updates, sales collateral, procurement responses, and campaign material.

It is not legal advice. It is a workflow checklist for collecting evidence-backed claims and avoiding unsupported broad impressions.

Why do green claims need stronger evidence?

Environmental claims often depend on scope, assumptions, time period, methodology, suppliers, offsets, lifecycle boundaries, and consumer interpretation. A short phrase can imply more than the team intended. “Sustainable” may imply broad environmental benefit. “Carbon neutral” may imply measured emissions, reduction activity, and credible offsets. “Recyclable” may depend on local facilities and product components.

Because interpretation matters, teams should govern both the wording and the surrounding qualification. Evidence should support the overall impression, not just one narrow fact.

Which green claims should be reviewed first?

Start with claims that are broad, prominent, comparative, or likely to influence buying decisions. These claims should not sit in general marketing copy without evidence and reviewer approval.

  • Sustainable, eco-friendly, green, planet-friendly, or environmentally responsible
  • Carbon neutral, net zero, climate positive, or lower carbon
  • Recyclable, compostable, biodegradable, or plastic-free
  • Made from sustainable materials or responsibly sourced
  • Lower emissions, reduced waste, reduced energy, or reduced water use
  • Comparisons against competitors, previous products, or industry standards

What evidence should support green claims?

Evidence should be specific to the product, service, geography, and claim. Supplier statements may help, but they may not be enough if the claim is broad. Methodology matters, especially for carbon, lifecycle, reduction, or offset-based claims.

If the claim depends on assumptions, exclusions, or a specific time period, those limitations should be visible in the approved wording or supporting qualification.

  • Lifecycle analysis, carbon accounting, or methodology documentation where relevant
  • Supplier evidence, material specifications, or chain-of-custody documents
  • Certification scope, issuing body, and validity period
  • Calculation notes for reductions, comparisons, or emissions numbers
  • Offset details if carbon neutrality depends on offsets
  • Exclusions, assumptions, geographic limits, and date range

Practical example: carbon claim

Proposed claim: “Our platform is carbon neutral.” Reviewers should ask whether this refers to company operations, product usage, hosting, supply chain, a specific year, or a subset of emissions. They should also ask whether the claim depends on offsets, reductions, renewable energy, or accounting assumptions.

A safer approved claim might be: “We offset measured operational emissions for 2025 through a verified offset programme.” This is still a claim that needs evidence, but it is clearer about scope and basis.

Green claims evidence checklist

Use this checklist before publishing sustainability or environmental wording.

  • Have we defined exactly what the green claim means?
  • Does the evidence support the overall impression created by the wording?
  • Is the claim specific about product, service, geography, and time period?
  • Have we avoided broad terms unless the evidence supports a broad interpretation?
  • Are assumptions, exclusions, and qualifications visible enough?
  • Is supplier or certification evidence current and in scope?
  • Have legal, sustainability, or compliance reviewers approved the wording?
  • Have we set a review date for evidence that may change?

How should teams govern approved green claims?

Green claims should be stored as approved wording with conditions for reuse. Teams should know which claims can be used on the website, in sales decks, or in campaign copy, and which claims need qualification. Evidence expiry matters because suppliers, materials, offset programmes, and methodology can change.

A claim approval workflow helps sustainability and marketing teams move faster without weakening substantiation. It also reduces the risk of teams reusing old environmental wording after the evidence changes.

FAQ: Can we use words like sustainable or eco-friendly?

Broad environmental words should be treated carefully. If the evidence only supports a narrow benefit, use narrower wording. If the broader phrase remains, make sure the qualification is clear and the evidence supports the overall impression.

FAQ: How does this relate to claims governance?

Green claims are a strong candidate for governance because they need evidence, reviewer decisions, approved wording, and review dates. Manage those records alongside other approved claims and evidence-backed claims.

Disclaimer

This checklist is informational only and is not legal or regulatory advice. Environmental claims should be reviewed by appropriate legal, compliance, and sustainability specialists.

Next step

Paste a page of copy into the Claim Risk Checker to find candidate claims and prioritise what needs evidence first.