Green Claims Audit
Environmental claims are now regulated on both sides of the Channel. The EU Empowering Consumers Directive (2024/825) applies from 27 September 2026, banning generic claims like “eco-friendly” and product-level carbon-neutral claims based solely on offsets. In the UK, the CMA gained direct enforcement powers under the Digital Markets, Competition and Consumers Act 2024 from 6 April 2025 — with fines of up to 10% of global turnover.
RSustain’s Green Claims Audit identifies non-compliant environmental claims across your marketing, packaging, and corporate reporting — before a regulator does.
The Regulatory Landscape
Multiple overlapping regimes now govern environmental claims made to consumers and investors. Organisations selling into the UK or EU need to satisfy all applicable requirements simultaneously.
EU: Empowering Consumers Directive
Directive (EU) 2024/825, amending the Unfair Commercial Practices Directive. Applies from 27 September 2026. Bans generic environmental claims (“green”, “eco-friendly”, “sustainable”) unless substantiated by recognised environmental performance. Prohibits product-level carbon-neutral claims based solely on carbon offsets. Durability, repairability, and recyclability claims must meet specific evidence standards.
UK: CMA & DMCC Act 2024
The Digital Markets, Competition and Consumers Act 2024 gave the CMA direct enforcement powers from 6 April 2025. The CMA can now impose fines of up to 10% of global turnover for misleading environmental claims — without needing a court order. The CMA’s Green Claims Code (6 principles) is the practical compliance benchmark.
ASA & Advertising Standards
The Advertising Standards Authority has intensified scrutiny of environmental claims. Rulings against major brands (including in apparel, energy, and FMCG) demonstrate that vague or unsubstantiated claims will be upheld. ASA rulings often precede CMA enforcement interest.
ISO 14021 & International Standards
ISO 14021:2016 (Environmental labels and declarations — Self-declared environmental claims) prohibits vague and non-specific claims. It provides the internationally recognised baseline for substantiation methodology, comparability requirements, and claim-specific tests.
What Our Green Claims Audit Covers
Claims Inventory
Systematic identification of every environmental claim across your website, packaging, product labels, annual report, social media, and advertising materials. Each claim is logged and categorised.
Compliance Assessment
Each claim tested against the CMA Green Claims Code (6 principles), the EU EmpCo requirements, ASA CAP/BCAP codes, and ISO 14021. RAG-rated risk register with specific remediation guidance.
Evidence Gap Analysis
Assessment of the data, certifications, and lifecycle evidence underpinning each claim. Identification of claims that lack substantiation and would not survive regulatory challenge.
Remediation Report
Prioritised action plan: which claims to withdraw, reword, or substantiate. Compliant alternative wording provided. Internal claims governance framework to prevent future exposure.
CMA Green Claims Code: 6 Principles
The CMA’s Green Claims Code requires that environmental claims must be:
- Truthful and accurate
- Clear and unambiguous
- Not omit or hide important information
- Only make fair and meaningful comparisons
- Consider the full lifecycle of the product or service
- Be substantiated with robust, credible, and up-to-date evidence
Our audit tests every identified claim against all six principles and provides specific, actionable findings for each.
Who Needs a Green Claims Audit?
Any organisation making environmental claims to UK or EU consumers, investors, or B2B customers. Sectors with elevated exposure include FMCG, apparel, food and beverage, energy, financial services (fund labelling), construction materials, and consumer goods. If your marketing uses terms like “sustainable”, “carbon neutral”, “net zero”, “eco-friendly”, or “recyclable” — these claims are now subject to enforcement.
Related Services & Resources
Frequently Asked Questions
Don’t Wait for a Regulator to Find the Problem
Book a free scoping call to discuss your environmental claims exposure and how RSustain can help you get compliant.
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