Green Claims Audit UK CMA Code · DMCCA 2024
The substantiation bar

Can I say "recyclable", "sustainable" or "eco-friendly" in the UK?

Blanket green words — "eco-friendly", "sustainable", "green", "recyclable", "natural" — are the most common failures under the CMA Green Claims Code, because they imply a whole-product benefit that is rarely evidenced. The Code doesn't forbid them outright, but it holds each to Principle 6 (substantiation) and Principle 5 (full life cycle): you either drop the vague word and state the specific, proven benefit, or you hold a recognised certification covering exactly that product and claim. Since the DMCCA 2024 came into force on 6 April 2025, a vague, unsubstantiated claim is one the CMA can act on directly. Only a court can decide an actual breach — so treat unproven blanket words as high-risk.

Why vague words are the number-one problem

"Eco-friendly", "green", "kind to the planet", "sustainable" — these read to a shopper as a broad, whole-life-cycle promise. Very few products can actually evidence that. The CMA's own review of environmental claims found this pattern everywhere: it reported that the overwhelming majority of some product categories were marketed as environmentally friendly, and treated blanket eco-statements with no evidence as a core concern. The Code's fix is blunt: make the word specific, or lose it.

"Sustainable" and "responsible"

These are broad, subjective words that need clear, accessible substantiation of the specific benefit and its scope across the life cycle. The CMA's fashion-sector work targeted exactly this language: the undertakings it accepted required retailers to use specific, clear terms like "organic" or "recycled" rather than ambiguous words such as "eco", "responsible" or "sustainable" without further explanation. If you keep "sustainable," pin it to what is sustainable, by how much, over what part of the life cycle, and where the evidence lives.

General information, not legal advice. This guide explains how the CMA Green Claims Code treats blanket environmental words. It is not legal advice, and only a court can decide whether a specific claim breaches the law.

"Recyclable"

A recyclability claim has to reflect reality, not theory. Under Principles 2, 5 and 6, "recyclable" should reflect whether the item is actually recycled in practice through UK kerbside or collection systems — not merely recyclable in a lab — and you must hold accessible evidence. An unqualified "100% recyclable" on an item that few UK councils actually collect is exactly the kind of claim that misleads. Qualify it (for example "widely recycled," where it meets the recognised on-pack recycling label test) and keep the supporting evidence.

"Natural", "biodegradable", "compostable"

  • "Natural" reads as an environmental or health benefit and needs clear substantiation of exactly what is being claimed — state the specific composition or sourcing you can prove.
  • "Biodegradable" needs a defined standard, timeframe and disposal environment, with the proof accessible; unqualified, it hides the conditions.
  • "Compostable" must distinguish home from industrial composting and be certified to a recognised standard — e.g. "industrially compostable, certified to EN 13432, where facilities exist."

How to make a blanket claim safely

  • Replace the vague word with the specific benefit — "made with 80% recycled aluminium" beats "eco-friendly" every time, and it's evidenceable.
  • Scope it to the life cycle stage it actually covers (Principle 5) — don't let a recycled-content claim imply the whole product and its packaging are covered.
  • Hold accessible evidence (Principle 6) — an LCA, test data or independent verification a consumer could reach.
  • Lean on a recognised certification, not a self-made badge — and only where the certification genuinely covers that product and claim.

Frequently asked questions

Can I call my product "eco-friendly" in the UK?

Blanket words like "eco-friendly", "green" or "kind to the planet" are high-risk under the Code unless a recognised certification covers exactly that product and claim. The CMA expects vague virtue-words dropped or replaced with a specific, proven benefit. Only a court can decide an actual breach.

What does "substantiated" mean under Principle 6?

Holding clear, credible, accessible evidence a consumer could reach — an LCA, test data, or independent verification. "We believe it's true" isn't substantiation; proof you hold and can show is.

Is "recyclable" safe to say?

Only if it reflects whether the item is actually recycled in practice through UK collection, not just recyclable in theory, and you hold accessible evidence. Qualify it — e.g. "widely recycled" where it meets the recognised on-pack label test — rather than an unqualified "100% recyclable".

Sources

Content current as of 9 July 2026. Guidance and the CMA/DMCCA position can change — re-check the primary source before acting on anything time-sensitive.

Not sure which of your words cross the line?

Paste your copy. We flag every blanket claim, the principle it fails, and rewrite it into a specific, provable form.

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