Greenwashing & Claims Compliance

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.

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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:

  1. Truthful and accurate
  2. Clear and unambiguous
  3. Not omit or hide important information
  4. Only make fair and meaningful comparisons
  5. Consider the full lifecycle of the product or service
  6. 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

What is the EU Empowering Consumers Directive?+

Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive to ban generic and unsubstantiated environmental claims. It applies from 27 September 2026. It prohibits claims like “eco-friendly” or “green” unless backed by recognised environmental performance, and bans product-level carbon-neutral claims based solely on offsets.

Can the CMA fine companies for greenwashing?+

Yes. Since 6 April 2025, the CMA has had direct enforcement powers under the Digital Markets, Competition and Consumers Act 2024. It can impose fines of up to 10% of global turnover for misleading environmental claims without needing a court order.

What does a green claims audit involve?+

A systematic review of all environmental claims across marketing, packaging, corporate reporting, and advertising. Each claim is tested against the CMA Green Claims Code, EU EmpCo, ASA codes, and ISO 14021. The output is a RAG-rated risk register with specific remediation actions and compliant alternative wording.

Can I still say “carbon neutral” on products?+

Under the EU EmpCo Directive (from September 2026), product-level carbon-neutral claims based solely on purchasing carbon offsets will be banned. In the UK, such claims must already meet the CMA Green Claims Code — meaning they must be truthful, substantiated, and not misleading. Offset-only claims are increasingly untenable in both jurisdictions.

What happened to the EU Green Claims Directive?+

The proposed Green Claims Directive (which would have required pre-approval of claims) has been effectively withdrawn as part of the EU’s Omnibus simplification package. The Empowering Consumers Directive (2024/825) is the operative law governing environmental claims in the EU.

How long does a green claims audit take?+

Typically 2–4 weeks depending on the number of products, channels, and markets. A focused audit of website and annual report claims can be completed in under 2 weeks.

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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