Green Claims Audit UK CMA Code · DMCCA 2024
A sign-off tool

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

  1. Truthful and accurate. Is every part of the claim true, and does the overall impression match reality — not just each word in isolation?
  2. 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?
  3. 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?
  4. Fair and meaningful comparisons. If you compare ("greener than…"), is the basis clear and the methodology equivalent across the things compared?
  5. Full life cycle. Is the claim true across the whole product and its packaging — or scoped precisely to the stage it actually covers?
  6. 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

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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