Self-made eco-labels and the Green Claims Code
An in-house "eco" or "ocean-friendly" badge that looks like an independent certification but is self-awarded is high-risk under the CMA Green Claims Code. Consumers read a seal as third-party endorsement, so a self-made one misleads by implying approval that does not exist — engaging Principle 2 (clear and unambiguous) and Principle 3 (not hiding important information), with Principle 6 (substantiation) applying to whatever the badge claims. Since the DMCCA 2024 came into force on 6 April 2025, that is a claim the CMA can act on directly. The Code doesn't ban you from making your own claim — it bans dressing a claim up as an endorsement. Only a court can decide an actual breach, so treat a self-made seal as high-risk.
Why a self-made seal misleads
The trap isn't the environmental claim itself — it's the format. A circular badge, a tick, a leaf-in-a-roundel, the words "certified" or "approved": these visual conventions tell a shopper "an independent body has checked this." When the "body" is your own marketing team, the badge implies an endorsement that never happened. That's a classic misleading impression, and it's squarely in the CMA's sights.
The principles a self-made label engages
- Principle 2 — clear and unambiguous. A self-awarded seal is ambiguous by design: it borrows the look of certification without the substance.
- Principle 3 — not omitting important information. The badge hides the single most important fact: that no independent body stands behind it.
- Principle 6 — substantiated. Whatever the badge asserts ("ocean friendly," "planet positive") still needs accessible evidence, exactly as a worded claim would.
General information, not legal advice. This guide explains how the CMA Green Claims Code treats self-made eco-labels. It is not legal advice, and only a court can decide whether a specific label breaches the law.
The Code reaches your whole visual identity
Self-made badges are one example of a wider point: the Code applies to your overall impression, not just your sentences. The CMA treats each of these as a potential green claim in its own right:
- Brand and product names that imply an environmental benefit ("Eco-", "Green-", "-Pure") — the name itself can be a claim that needs substantiating.
- Visual identity — a leaf motif, a green colour palette, nature imagery — can create an "eco" impression even where no word makes the claim.
- Third-party logos you display — these must come from a scheme that genuinely covers your product; verify each one qualifies and is current, or it becomes a misleading endorsement too.
What to do instead
- Use a recognised independent certification you actually hold — one that genuinely covers that product and claim — and be ready to show it. A certification on one product line does not license a badge across the whole range.
- If you keep an in-house mark, make it unmistakably your own claim, not an endorsement — and tie it to a specific, substantiated benefit rather than a vague virtue.
- Drop borrowed certification cues — "certified," "approved," tick-and-roundel styling — unless an independent body has, in fact, certified or approved it.
- Check your name, palette and imagery against the six principles, not just your copy.
Frequently asked questions
Can I put my own "eco" badge on my products?
A self-awarded badge that looks like an independent certification is high-risk under the Code, because consumers read it as third-party endorsement. Keep it only if it is unmistakably your own substantiated claim, or replace it with a recognised independent certification you actually hold. Only a court can decide an actual breach.
Which Green Claims Code principles do self-made labels fail?
Chiefly Principle 2 (clear and unambiguous) and Principle 3 (not omitting or hiding important information), with Principle 6 (substantiation) applying to whatever the badge claims.
Do brand names and logos count as green claims?
Yes. A brand name, product name, in-house seal, leaf motif or green palette can each be an environmental claim in its own right, and must meet the same six principles as any worded claim.
Sources
- CMA Green Claims Code (2021) — Principles 2, 3 and 6, and its guidance that names, logos and imagery can be claims. gov.uk — Green Claims Code
- CMA guidance: "Making environmental claims on goods and services" — the detailed CMA guidance covering labels, logos and overall impression. gov.uk — How to make environmental claims about products and services
- Digital Markets, Competition and Consumers Act 2024 — the unfair-trading provisions (Part 4) that catch misleading labels; in force 6 April 2025. legislation.gov.uk/ukpga/2024/13
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.
Got an in-house badge you're unsure about?
Paste your copy and tell us what certifications you hold. We flag self-made-label risk, the principle it engages, and what to do instead.
Check my green claims → get my report