Claims register · evidence · CMA
Green claims software: every claim, its evidence
Green claims software keeps a register of every environmental claim a business makes and the evidence behind each one.
Since the DMCC Act, the CMA can enforce consumer law directly, so an unsubstantiated claim is a financial risk, not only a reputational one.
The guidance is explained on the Green Claims Code guide.
The Code
Which principles should green claims software check?
The CMA’s Green Claims Code sets six principles (CMA).
| Principle | What the software should hold |
|---|---|
| Truthful and accurate | The measurement behind the claim |
| Clear and unambiguous | The exact wording published, by channel |
| Must not omit or hide important information | Known limitations and exclusions |
| Fair and meaningful comparisons | The comparator and its basis |
| Consider the full life cycle | The life cycle stages covered |
| Substantiated | The evidence, its date and owner |
Liability
Why does green claims software need supplier evidence?
The CMA says liability for a green claim runs along the whole supply chain, an innocent breach is still a breach in civil enforcement, and due diligence is not a defence (CMA).
So a retailer repeating a supplier’s claim needs the supplier’s evidence in its own register.
Under the DMCC Act the CMA can impose consumer-law penalties directly; the Act contains two different "10% of turnover" penalties in different parts with different mechanics (DMCC Act).
Carbon claims
What about carbon neutral and net zero claims?
No UK instrument targets carbon or offsetting claims specifically; general misleading-practices law applies (DMCC Act Part 4).
The ASA treats an unqualified "carbon neutral" claim as misleading (ASA).
See carbon neutral software and product carbon footprint software.
The demonstration
What should you test before buying?
Load five live claims from your packaging and website.
Software demo · evidence check
Green claims demo coverage
Tick a test only when the vendor has demonstrated it with a representative record and shown the evidence or export.
0 of 5 tests demonstrated (0%). This is a checklist result, not a score for the vendor.
Still to test: Record each claim’s exact wording, channel and date published; Attach the evidence and its expiry or review date; Hold supplier evidence for any claim you repeat; Flag a claim whose evidence is out of date; Export the register for legal review.
Frequently asked
Green claims software, answered
What is green claims software?
Software that registers each environmental claim a business makes, links it to the evidence that substantiates it, and flags claims whose evidence is out of date or missing.
Is the Green Claims Code law?
No. It is the CMA’s guidance on its view of the law, but a business that ignores its principles is more likely to attract the CMA’s attention, and consumer law itself is enforceable.
Who is liable for a misleading green claim?
The CMA says liability can run along the whole supply chain, an innocent breach is still a breach in civil enforcement, and due diligence is not a defence.
Has the CMA fined anyone for greenwashing?
Its record so far is undertakings and closures, all before DMCC direct enforcement began; do not assume a fine has been imposed unless a case page says so.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- CMAGreen Claims Code: environmental claims on goods and services
- CMAMaking green claims: getting it right across the supply chain
- LegislationDigital Markets, Competition and Consumers Act 2024, Part 4
- LegislationDMCC Act 2024, section 182
- LegislationDMCC Act 2024, section 204
- CMAASOS, Boohoo and Asda greenwashing investigation
- ASACAP Code section 11: environmental claims
- European ParliamentGreen Claims Directive procedure 2023/0085(COD)
- EUR-LexDirective (EU) 2024/825, empowering consumers
- ISOISO 14067:2018