All-natural.
Biodegradable.
Planet-friendly.
Sustainable.
They all sound wonderful. But do they mean what we think they mean?
To make good buying choices, we should be able to rely on clear evidence for environmental and sustainability claims. Alas, broad and unsubstantiated green claims in advertising and product labelling are common and often intentionally misleading. The good news is that regulatory and industry bodies in the UK and elsewhere are responding with new enforcement measures and guidance to ensure the trustworthiness of green claims.
How prevalent is greenwashing?
According to the latest RepRisk report, greenwashing incidents decreased 12% globally across all sectors in 2024, largely attributed to new legislation in the EU and the UK and increasing politicization of environmental, social and governance (ESG) action in the US.
But despite a 3.7% drop in UK greenwashing risk incidents, the temptation to overstate environmental claims persists at large firms. The UK Advertising Standards Authority (ASA) watchdog continues to find against household names such as Lloyds Bank and Virgin Atlantic for overstating environmental benefits.
New legislation and industry standards have been developed to tackle the persistent problem of greenwashing. Here is an overview of the most important measures now in effect.
Digital Markets, Competition and Consumers (DMCC) Act
The DMCC Act 2024 came into effect in April 2025 and marks a major shift in UK consumer protection. It grants the Competition & Markets Authority (CMA) direct powers to investigate and take action on greenwashing and other misleading practices in high consumer impact sectors like fashion and finance. The Act also gives the CMA the teeth to enforce consumer law, including imposing fines of up to 10% of global turnover on firms or £300,000 for individuals.
Financial Conduct Authority (FCA) Anti-Greenwashing Rule
Effective as of 31 May 2024, the FCA Anti-Greenwashing Rule applies to financial services and investment products. It requires all authorised firms to ensure sustainability references are:
- correct and capable of being substantiated
- clear and presented in a way that can be understood
- complete, not omitting or hiding important information and considering the full life cycle of the product or service, and that
- comparisons to other products and services are fair and meaningful
Green Claims Code
Not a law itself, the CMA’s Green Claims Code is used as a benchmark for assessing misleading environmental and sustainability claims. Compliance with the code is enforceable under consumer protection law, now strengthened by the DMCC Act, and states that green claims must:
- be truthful and accurate
- be clear and unambiguous
- not omit or hide important information
- only make fair and meaningful comparisons
- consider the full life cycle of the product
- be substantiated
Anti-Greenwash Charter
Launched in 2022, the Anti-Greenwash Charter is a not-for-profit initiative that has become a trusted benchmark for credible sustainability communications. Certified signatories gain the right to display the Anti-Greenwash Charter logo. Our friends at Select First and Gunnebo have joined as signatories, and our fellow 1% for the Planet and B Corp besties at Hattrick collaborate on training and research. UK and international organisations are welcome to apply to join the Charter, and approval commits organisations to four core standards:
- Transparency: Clear communication of sustainability benefits, ensuring no important information is concealed or omitted
- Accountability: Substantiated claims with accurate, empirical evidence that is regularly evaluated
- Fairness: The use of fair, clear, and unambiguous language when making comparisons with other products or organisations
- Honesty: Specific, truthful statements about sustainability efforts, and ensuring actions align with your promises
Advertising Standards Authority (ASA)
The advertising industry self-regulates environmental claims using the ASA as its enforcement body backed by Trading Standards and now the DMCC. The ASA’s reach extends to advertising claims across all media, including online and social media influencer content. A public register of ASA rulings detailing case histories exerts reputational pressure on firms and their marketing and advertising departments and partners.
British Promotional Merchandise Association (BPMA) Anti-Greenwashing Guidance
In May 2025 the BPMA released new guidance for its members — including our friends at Sharon Lee — to help recognise and avoid “exaggerated or unsubstantiated environmental claims”. A strong example of industry anti-greenwashing support, the BPMA’s guidance is non-binding but advises its membership to:
- check compliance with the CMA’s Green Claims Code
- dedicate website space to showcase sustainability
- consider carefully when selecting marketing imagery and labels
- avoid bold and unsubstantiated claims
- educate teams to ensure alignment with environmental values
- verify environmental claims and data with trusted third parties
EU Green Claims Directive
The EU Green Claims Directive, officially Directive 2024/825, aims to combat greenwashing by requiring companies to substantiate environmental claims using robust, science-based methods. It also mandates that all voluntary green claims be independently verified and complements Empowering Consumers for the Green Transition (ECGT) Directive product labelling rules. EU member states have a deadline of 27 March 2026 to transpose the directive into national law. From this date, UK companies trading in the EU will need to comply with these rules to access the single market.
Need help?
At Grain we have wide experience supporting clients with legal and voluntary sustainability framework compliance. We’re also experts in sustainability communications and can help you get your messages across to your audience effectively and in the right way.
