Green claims rules for UK food and drink brands: what the CMA expects

Why food and drink is in the CMA's line of sight

The CMA started with fashion. It then turned to fast-moving consumer goods — the everyday things people buy on autopilot, food and drink among them. When it flagged that work, it pointed out how saturated these categories are with environmental branding: in some, the great majority of products on shelf carried some kind of "green" message. Where a claim is on nearly everything, a misleading one shapes real purchasing decisions at scale, which is precisely the harm consumer law is meant to stop.

There's a second reason food gets attention. The claims are dense and they stack. A single drinks carton can carry a recyclability logo, a "natural" flag, a carbon badge and a "responsibly sourced" line all at once — four separate environmental claims, each of which has to be true, clear and backed by evidence on its own. The more claims you crowd onto a pack, the more surface area you give a regulator or a competitor to challenge.

The four claims that get food and drink brands into trouble

These are the recurring problem words. None is banned. Each is high risk when it's unqualified or unsupported.

"Recyclable"

The classic trap. A bare "recyclable" (or a recycling logo) implies the consumer can actually recycle the pack. If the material — a laminated pouch, a black plastic tray, a mixed-material carton — isn't collected by household schemes in practice across the UK, that implication is misleading even when the material is technically recyclable somewhere. The honest version says what's recyclable and where: which component, and whether it's widely collected or needs a store drop-off or a "check locally". Recyclability was one of the specific concerns the CMA named in its FMCG work.

"Natural"

"Natural" reads to a shopper as both healthier and greener, and it rarely says what it actually refers to. Some ingredients have a defined meaning under food-labelling rules, but slapped on the front of pack as a mood, "natural" is a broad claim you have to be able to justify for the whole product. A "natural" badge on something with processed, synthetic or heavily refined components is hard to defend. If you use it, tie it to a specific, true fact — "made with natural flavourings", not a free-floating "natural".

"Sustainable" / "responsibly sourced"

These are the vaguest of the lot, and vagueness is the problem. "Sustainable" on its own tells the consumer nothing they can check, and the Code expects claims to be specific and substantiated. "Responsibly sourced" is only meaningful if you can say what the responsibility is and prove it — a named certification scheme, a defined standard, an audited supply chain. Whole ranges branded "sustainable" with nothing behind the word were among the exact issues the CMA raised in everyday-essentials categories.

"Carbon neutral"

The highest-scrutiny claim in the set. When "carbon neutral" rests mainly on buying offsets rather than on real cuts to your own emissions, it's easy to mislead — the shopper hears "no climate impact", the reality is "we paid someone else". The ASA has ruled several offset-based neutrality ads misleading, and the CMA treats these claims as high risk. If you make one, be transparent about what it covers and how it's achieved, and don't let "neutral" imply more than offsets can deliver.

How the six principles land on a food label and an ad

The CMA Green Claims Code sets out six principles. They read as abstract until you hold a real pack against them. Here's how they apply to, say, a "100% natural, recyclable, carbon-neutral" smoothie bottle and the ad that promotes it:

• Be truthful and accurate. Every claim has to be literally true. If the bottle body is recyclable but the sleeve and cap aren't, "recyclable" without qualification isn't accurate.
• Be clear and unambiguous. "Natural" must mean to the shopper what you can back up. If it reads as "healthy and additive-free" but the product has additives, the claim misleads even if you meant something narrower.
• Not omit or hide important information. A carbon-neutral badge that hides its reliance on offsets, or a recyclability logo that hides "not collected in most areas", omits the thing the consumer needs.
• Only make fair and meaningful comparisons. "Greener bottle" only works if you say greener than what, and the comparison is like-for-like.
• Consider the full life cycle. A claim can't cherry-pick one green feature while ignoring a bigger impact elsewhere — a recyclable pack around an air-freighted product, for instance.
• Be substantiated. You need the evidence to hand before the claim goes on the pack or into the ad, not assembled after a challenge lands.

The same six apply to the advert word-for-word. A green claim doesn't get a lighter standard because it's in a 30-second spot instead of on the label — if anything, an ad has less room to qualify, so the claim has to be safer to start with.

The teeth: direct CMA enforcement and 10% fines

What changed the stakes is the Digital Markets, Competition and Consumers Act 2024. Its unfair-commercial-practices regime came into force on 6 April 2025, and it lets the CMA decide for itself that a business has broken consumer protection law and impose a penalty directly — up to 10% of worldwide turnover — without first winning a court case. Before this, the CMA generally had to go to court to force the point. Now the decision, and the fine, can come from the CMA.

For a food or drink brand — often part of a group with large global revenue — 10% of worldwide turnover is not a rounding error. And it's not only the CMA. The ASA polices green claims in advertising under the CAP Code, so a misleading eco-ad can draw an ASA ruling as well. The practical takeaway: a claim now has to survive two regulators and a self-assessed penalty regime, so the margin for a loose word on a pack is a lot thinner than it was two years ago.

What to actually do before a claim ships

• List every environmental claim on the pack and in the campaign — words, logos, colours and imagery that imply "green" all count.
• Swap vague for specific. "Responsibly sourced" becomes a named scheme; "recyclable" becomes "bottle widely recycled, cap not yet"; "natural" gets tied to a real, provable fact.
• Pull the evidence now, not later. If you can't produce the substantiation today, the claim isn't ready.
• Check the whole-product picture so one green feature isn't masking a bigger impact.
• Hold ads to the same bar as packaging, and remember the ASA is watching the ad too.

Frequently asked questions

Sources

• CMA Green Claims Code — "Making environmental claims" — the six principles that apply to every UK environmental claim, including on food and drink. gov.uk — Green Claims Code: making environmental claims
• CMA: green claims in household essentials (FMCG) — the CMA's extension of its green-claims work into fast-moving consumer goods and everyday essentials. gov.uk — CMA to scrutinise green claims in household essentials
• Digital Markets, Competition and Consumers Act 2024 — the unfair-practices regime (in force 6 April 2025) and the CMA's direct-enforcement and penalty powers of up to 10% of global turnover. legislation.gov.uk — DMCCA 2024
• Advertising Standards Authority / CAP Code — the rules on environmental claims in advertising, which run alongside the CMA regime. asa.org.uk — CAP Code, environmental claims

Content current as of 9 July 2026. Guidance and enforcement evolve — check the CMA's and ASA's own pages for the latest position before acting on anything time-sensitive.