A green claims compliance checklist: the six principles as a sign-off
Before you print, publish or advertise any environmental claim, run it through the CMA Green Claims Code's six principles — and then check your labels, names and imagery, because the Code applies to your whole impression, not just your words. The checklist below turns the six principles into sign-off questions. It's a practical risk-reduction tool, not a legal ruling: passing it lowers your risk under the Code and the DMCCA 2024, but only a court can decide whether a claim actually breaches the law. Treat anything you can't tick with confidence as a prompt to fix the claim or get advice before you spend on relabelling.
Part 1 — the six principles, as questions
- Truthful and accurate. Is every part of the claim true, and does the overall impression match reality — not just each word in isolation?
- Clear and unambiguous. Would a typical customer understand exactly what benefit you're claiming, without filling in gaps more generously than the facts allow? Have you replaced vague words ("eco", "green", "sustainable") with a specific benefit?
- No important information omitted. Have you included every caveat that changes how the claim reads — conditions, scope, reliance on offsets — close enough to the claim to be seen?
- Fair and meaningful comparisons. If you compare ("greener than…"), is the basis clear and the methodology equivalent across the things compared?
- Full life cycle. Is the claim true across the whole product and its packaging — or scoped precisely to the stage it actually covers?
- Substantiated. Do you hold clear, credible, accessible evidence a consumer could reach (an LCA, test data, independent verification)?
General information, not legal advice. This checklist is a practical aid based on the CMA Green Claims Code. It is not legal advice, and only a court can decide whether a specific claim breaches the law.
Part 2 — beyond the words
The Code reaches your labels and design too. Check each:
- Self-made badges. Does any in-house "eco"/"ocean" seal read as an independent endorsement it isn't? If so, remove it or replace it with a recognised certification you actually hold.
- Brand and product names. Does the name ("Eco-", "Green-", "-Pure") imply a benefit that needs substantiating?
- Imagery. Do a leaf motif, a green palette or nature imagery create an "eco" impression the product can't back up?
- Third-party logos. Does every certification logo you display come from a scheme that genuinely covers this product, and is it current?
Part 3 — evidence you should be able to produce
- Specific benefit claim → the LCA, test data or independent verification behind it, accessible to a consumer.
- Blanket "green"/"eco" word kept → a recognised certification covering exactly this product and claim (or drop the word).
- Future target ("net zero by …") → a clear, costed, publicly available plan with independently verified interim milestones, presented as a target, not a present fact.
- Recyclability → evidence it's actually recycled in practice through UK collection, not just recyclable in theory.
- Certification scope → confirmation the certification covers each blanket claim you keep (a cert on one line doesn't license a claim across the range).
Part 4 — if it runs in advertising
A claim in a paid ad must also satisfy the ASA's CAP/BCAP Code, on top of the Green Claims Code and the DMCCA. A claim written to pass the six principles will usually clear the CAP Code too — but have marketing sign off ad copy against the CAP Code as a separate step, especially for any carbon-neutral or net-zero wording.
Part 5 — the honest limit
A checklist reduces risk; it does not certify compliance. The DMCCA regime is live, with no grace period, and the CMA can fine up to £300,000 or 10% of worldwide turnover, whichever is greater, for a consumer-law breach. A claim you can't confidently tick, or one that's high-stakes, should go to qualified counsel before it goes to print.
Frequently asked questions
What should a green claims compliance checklist cover?
Each claim against the six principles — truthful and accurate, clear, not omitting information, fair comparisons, full life cycle, and substantiated — plus your labels, names, imagery and third-party logos, because the Code applies to your overall impression, not just your words.
Does passing this checklist make my claim legally compliant?
No. It's a practical sign-off aid, not a legal ruling. Passing it reduces risk, but only a court can decide whether a claim breaches the law. Treat anything you're unsure about as a prompt to get qualified advice.
Does the checklist apply to advertising too?
Yes. If a claim runs in advertising it must also satisfy the ASA's CAP/BCAP Code, on top of the CMA Green Claims Code and the DMCCA 2024. Have marketing sign off ad copy against it as well.
Sources
- CMA Green Claims Code (2021) — the six principles this checklist is built from, plus its guidance on labels, names and imagery. gov.uk — Green Claims Code
- CMA guidance: "Making environmental claims on goods and services" — the detailed CMA guidance behind the principles. gov.uk — How to make environmental claims about products and services
- ASA/CAP: environmental claims (general) — the advertising rules a claim must also meet if it runs in ads. asa.org.uk — Environmental claims: general
- Digital Markets, Competition and Consumers Act 2024 — the enforcement regime and penalties; 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.
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