The law
Misleading actions and omissions in the DMCC Act 2024, Part 4.
In force since 6 April 2025.Consumer law · environmental claims
The Green Claims Code
The Green Claims Code is the CMA’s guidance on making environmental claims without misleading consumers, built on six principles.
It is not law in itself, but since 6 April 2025 the CMA can enforce the consumer law behind it directly.
A breach can cost up to £300,000 or 10% of worldwide turnover, whichever is higher.
The six principles
What are the six principles of the Green Claims Code?
Truthful, clear, complete, fair in comparison, whole life cycle, and substantiated.
The Code covers claims about products and services, and about a brand or a business as a whole (CMA).
It was published on 20 September 2021 and has not been rewritten since; the CMA’s 22 January 2026 guidance supplements it.
Six principlesExplore
Six principles
Full life cycle
“Claims must consider the full life cycle of the product or service”.
Status
Is the Green Claims Code law?
No. It is the CMA’s view of the law, and the law behind it is the DMCC Act.
The Code still cites the 2008 regulations that the DMCC Act repealed (s.252).
The CMA said on 22 January 2026 that the new law broadly mirrors the old, so its guidance “continue[s] to apply in substance” (CMA).
The consumer’s own redress rights under the new Act, such as unwinding a contract, have not yet been brought into force (SI 2025/272).
An environmental claim to consumers
The CMA’s guidance
The Green Claims Code and the 22 January 2026 supply-chain guidance.
Still applies in substance.The advertising rules
CAP Code section 11, enforced by the ASA.
Not law, but the CMA can weigh a breach.One claim
What happens to one retailer’s “carbon neutral” claim?
It is lawful but probably misleading, and the ceiling on a fine is 10% of worldwide turnover.
It is an illustration, not a real retailer or case.
The figure is a ceiling the Act allows, not a fine anyone has been given.
- 1
The claim
A UK retailer labels a range “carbon neutral”, relying on offsets, with no explanation on pack.
- 2
Is it banned?
No: UK law has no specific rule on offset-based claims (DMCC Act Sch 20).
- 3
Is it a problem?
Probably: the ASA treats an unqualified “carbon neutral” claim as misleading, and the Code wants nothing important hidden (CAP Code s.11).
- 4
What could it cost?
With £40,000,000 worldwide turnover, the ceiling is £4,000,000, being 10% and higher than £300,000 (s.182(6)).
- 5
Who else is exposed?
Its supplier, if the supplier made the claim the retailer repeated (CMA, 22 January 2026).
Penalties
What can the CMA fine for a green claim?
Up to £300,000 or 10% of worldwide turnover, whichever is higher, since 6 April 2025.
| Breach | Ceiling | Provision |
|---|---|---|
| A misleading claim the CMA finds infringes consumer law | £300,000 or, if higher, 10% of turnover | DMCC Act s.182(6) |
| The same, through a court on a public enforcer’s application | The same ceiling | s.158(5) |
| Ignoring the CMA’s directions afterwards | £150,000 or, if higher, 5% of turnover, plus a daily amount | s.193(3) |
Your claim
Does your claim pass the six principles?
Tick what the claim already meets, enter turnover, and see the gaps and the ceilings.
A tick means you hold the evidence today, not that you could find it if asked.
Substantiation is the principle most often missing, because the claim is drafted before the evidence is gathered.
Green Claims Code · test a draft claim
Tick the principles the claim meets, and enter turnover to see the penalty ceilings.
Principles: CMA Green Claims Code (20 September 2021). Ceilings: Digital Markets, Competition and Consumers Act 2024 s.182(6) and s.193(3)(a); turnover under s.204.
A ceiling, not a likely fine. The Code is the CMA’s guidance, not law. Nothing you enter leaves your browser.
Enforcement
Has the CMA taken action on green claims?
Undertakings and closures, before its fining powers existed; no fines.
- 29 July 202201
- 12 December 202302
- 27 March 202403
- 6 November 202404
We found no published CMA case under its new powers on environmental claims as at 15 October 2026; the CMA’s case list was not filtered directly.
The FCA rule
How is the Code different from the FCA anti-greenwashing rule?
The CMA covers claims to consumers by anyone; the FCA rule covers authorised firms’ product claims.
| CMA Green Claims Code | FCA anti-greenwashing rule | |
|---|---|---|
| Who it binds | Any business dealing with consumers | FCA-authorised firms |
| What it covers | Product, brand and business claims | Claims about a product’s or service’s sustainability characteristics |
| A firm’s claims about itself | Covered | Not covered by ESG 4.3.1R; back to the CMA, the ASA and the FCA Principles |
| Since | The law behind it: 6 April 2025 | 31 May 2024 |
| Sanction | £300,000 or 10% of turnover, if higher | The FCA’s general powers |
The FCA rule in full is on the FCA anti-greenwashing rule.
Order of work
What should a business do first?
List every environmental claim you make, then test each against the six principles before it goes out.
Claims built on offsets or credits need particular care; see carbon offset strategy.
Claims of carbon neutrality made under a standard are compared on PAS 2060 and ISO 14068.
- 1
List every claim
Packs, product pages, adverts, the website and the annual report.
- 2
Find the evidence for each
Before the claim is used, not after a complaint.
- 3
Qualify neutrality claims
Say what is offset and what is reduced.
- 4
Check your suppliers’ claims
Repeating a supplier’s claim can make it yours.
- 5
Review regularly
A claim true last year can mislead this year.
The CMA can now fine a misleading green claim without going to court, so the evidence has to exist before the claim does.
- Six principles
Truthful, clear, complete, fair, whole life cycle, substantiated
The CMA’s test for any environmental claim. - 6 April 2025
The CMA can fine without going to court
Under the DMCC Act. - £300,000 or 10%
The ceiling is whichever is higher, on worldwide turnover
Never a bare 10%. - 22 January 2026
Liability runs along the supply chain
An innocent breach is still a breach. - No UK ban
Offset-based “carbon neutral” claims are lawful unless they mislead
The EU banned them from 27 September 2026.
What about the EU rules on green claims?
The EU banned offset-based product neutrality claims from 27 September 2026; the UK has no equivalent.
A campaign run in both the UK and the EU now has to meet the stricter EU rule in the EU.
The EU sideExplore
The EU side
Empowering Consumers Directive
Claims that a product is neutral, reduced or positive because of offsets are banned from 27 September 2026.
The EU side
Green Claims Directive
Not withdrawn; awaiting the Council’s first-reading position.
Frequently asked
What else do people ask about the Green Claims Code?
What is the Green Claims Code?
It is the Competition and Markets Authority’s guidance, published on 20 September 2021, on how businesses can make environmental claims without breaking consumer law.
It sets six principles and covers claims about products, brands and businesses as a whole.
It is guidance on the CMA’s view of the law, not law itself.
What are the six principles of the Green Claims Code?
Claims must be truthful and accurate; claims must be clear and unambiguous; claims must not omit or hide important relevant information; comparisons must be fair and meaningful; claims must consider the full life cycle of the product or service; claims must be substantiated.
Can the CMA fine a business for greenwashing?
Yes, since 6 April 2025.
Under the Digital Markets, Competition and Consumers Act 2024 the CMA can decide for itself that consumer law has been broken and impose a penalty of up to £300,000 or, if higher, 10% of worldwide turnover.
Ignoring its directions afterwards can add up to £150,000 or 5% of turnover.
Has the CMA fined anyone for green claims?
Not on the cases found.
ASOS, Boohoo and George at Asda signed formal agreements in March 2024, and the Unilever investigation closed in November 2024 without the CMA taking a view.
We found no published CMA case under its new powers on environmental claims as at 15 October 2026.
Are carbon neutral claims banned in the UK?
No. They are lawful unless they mislead, and the ASA’s position is that an unqualified “carbon neutral” claim is likely to.
The EU banned offset-based product neutrality claims from 27 September 2026, but the UK has no equivalent rule.
Is the Green Claims Code out of date?
It still cites the 2008 regulations that the DMCC Act repealed, but the CMA said on 22 January 2026 that its guidance continues to apply in substance. It remains the CMA’s current view of the law.
How is the Green Claims Code different from the FCA anti-greenwashing rule?
The Code is the CMA’s guidance for any business making claims to consumers.
The FCA rule binds FCA-authorised firms’ claims about their financial products and services, from 31 May 2024.
A financial firm’s claims about itself fall outside the FCA rule and back under the CMA and ASA.
Sources
Where does each figure come from?
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 14 sources fromCompetition and Markets Authoritylegislation.gov.ukASA / CAPEUR-LexEuropean ParliamentFCA Handbook
- Competition and Markets AuthorityMaking environmental claims on goods and services (the Green Claims Code)
Published 20 September 2021: the six principles.
- Competition and Markets AuthorityMaking green claims: getting it right across the supply chain (22 January 2026)
Liability runs along the supply chain; the CMA can now decide infringements itself.
- Competition and Markets AuthorityFashion greenwashing: ASOS, Boohoo and Asda
Opened 29 July 2022; closed 27 March 2024 with formal agreements.
- Competition and Markets AuthorityFast Moving Consumer Goods (Unilever)
Opened 12 December 2023; closed 6 November 2024 without a view on compliance.
- legislation.gov.ukDigital Markets, Competition and Consumers Act 2024, Part 4
The unfair-trading prohibitions; Schedule 20’s blacklist says nothing about carbon.
- legislation.gov.ukDMCC Act 2024 s.182(6)
A penalty of up to £300,000 or, if higher, 10% of turnover.
- legislation.gov.ukDMCC Act 2024 s.193
Breaching CMA directions: up to £150,000 or, if higher, 5% of turnover.
- legislation.gov.ukDMCC Act 2024 s.204
Turnover is worldwide and group-wide.
- legislation.gov.ukDMCC Act 2024 s.252
The Consumer Protection from Unfair Trading Regulations 2008 are repealed.
- legislation.gov.ukSI 2025/272, reg 2
Parts 3 and 4 Chapter 1 commenced on 6 April 2025, except the consumer redress rights.
- ASA / CAPCAP Code section 11: environmental claims
Unqualified “carbon neutral” claims are likely to mislead.
- EUR-LexDirective (EU) 2024/825, Annex I point 4c
Offset-based product neutrality claims banned in the EU from 27 September 2026.
- European ParliamentProcedure 2023/0085(COD), Green Claims Directive
Not withdrawn; awaiting the Council’s first-reading position.
- FCA HandbookESG 4.3.1R, the anti-greenwashing rule
Applies to authorised firms’ product and service claims from 31 May 2024.
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