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Which? claims widespread breaches of green marketing rules

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Consumer group Which? has recently carried out a review of green claims from 1,000 online product listings from UK retailers. It published the results earlier this month (2 July 2025) claiming high levels of non-compliance. Notably, it states that 84% of product claims failed at least one principle of the Green Claims Code, and 62% failed on multiple counts.

Which? are calling for greater enforcement of the existing rules, as well as increased support for businesses seeking to comply, to improve consumer confidence in claims and empower consumers seeking to make purchasing choices based on environmental factors.

The Competition and Markets Authority (CMA) published the Green Claims Code in 2021, setting out guidance for businesses as to compliance with their obligations under consumer law when making environmental claims, and setting out the CMA’s areas of focus when assessing claims. The Code sets out 6 key principles when making green claims, which are:

  1. Be sure claims are truthful and accurate
  2. Be sure claims are clear and unambiguous
  3. Be sure claims don’t omit or hide information
  4. Only make fair and meaningful comparisons
  5. Substantiate any claims made
  6. Consider the full life cycle of a product

A significant proportion of the identified non-compliant claims related to lack of clarity, information or substantiation. It is an important reminder that even claims based on legitimate green credentials may be in breach of consumer law if consumers are not clear of the extent of the claim being made or the basis for it. 

CMA enforcement to date has largely been sector-focused; securing undertakings from businesses across fashion, consumer products and green-heating. However, given the apparent widespread non-compliance identified by Which? it remains to be seen whether the CMA will shift its approach and seek to utilise its direct enforcement powers under the Digital Markets Competition and Consumers Act 2024.

Get in touch if you would like to discuss your advertising and green claims.