If your business makes environmental claims, even modest ones, the rules around them changed at the start of the year. Here’s what’s new, what it means for you, and what to do about it.
What Changed, in Short
On 22 January 2026, the Competition and Markets Authority (CMA) published new guidance updating the Green Claims Code. The substance:
- “Making” a claim now includes repeating one. If you put a supplier’s environmental claim on your website or packaging, it counts as your claim too.
- The CMA can fine up to 10% of global turnover directly, without going to court. This has been in force since April 2025.
- An “innocent” or “unwitting” breach is still a breach. Acting in good faith helps with penalties, but it isn’t a complete defence.
The Code’s six core principles haven’t moved. Who carries the risk has. Accountability has shifted downstream; if your name is on the claim, the risk sits with you.
And it’s Being Enforced
In February 2026, the Advertising Standards Authority upheld complaints against two infant care companies for using “sustainable”, “eco” and “biodegradable” without sufficient evidence. Travel agents had the same treatment in December 2025. Neither group were large multinationals. Enforcement is no longer theoretical, and a ‘we’re not big enough to be noticed’ approach comes with risk.
The Claims Most Likely to Attract Attention
- Standalone “eco”, “sustainable” or “green” with no further explanation
- Recyclability or biodegradability claims without the conditions specified (for example, “industrially compostable only”)
- Recycled content figures that apply to one component but read as the whole product
- Carbon neutral claims relying on offsets you haven’t disclosed
- Logos and certifications lifted from supplier marketing without checking they apply to your specific product
This isn’t a list of claims to avoid. It’s a list of claims that need evidence behind them.
A Workable Response
The CMA’s approach is risk-based and proportionate. You’re not expected to audit your entire supply chain. You are expected to ask, document, and verify in proportion to what you’re claiming.
Four practical steps:
- Hold the evidence. For every environmental claim on your channels, keep the substantiation on file, including for claims that came from a supplier.
- Push the obligation upstream. Update supplier contracts to require evidence and indemnity for any claim you may repeat.
- Drop the vague absolutes. “Sustainable”, “eco-friendly” and “green” on their own carry the most risk. Replace them with something specific or take them out.
- Show your work. Document your verification process. Genuine compliance effort is explicitly treated as a mitigating factor when the CMA sets penalties.
The Steer
This isn’t a regulator looking to make examples of well-run small businesses. It’s a tidying-up of a decade of loose green marketing, and the businesses that draw scrutiny first will be the ones whose claims look least defensible on inspection. Those that have done the work, even imperfectly, sit comfortably outside that group.
If you’d like us to review your claims against the new Code and tell you what stands and what doesn’t, get in touch. It’s a short engagement and worth doing before the regulator decides for you.
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