Green Claims, Red Flags: UK Product Descriptions May Fall Foul of the CMA’s Green Claims Code – The National Law Review

Report on Environmental Claims and Their Alignment with Sustainable Development Goals

Introduction: Assessing Corporate Contributions to SDG 12

A 2025 policy research report by London Economics provides a critical analysis of environmental claims on products in the United Kingdom, evaluating their alignment with principles of transparency and accountability central to the Sustainable Development Goals (SDGs). The research utilized artificial intelligence to assess nearly 10,000 products against the UK Competition and Markets Authority’s (CMA) Green Claims Code. This Code serves as a key national instrument for advancing SDG 12 (Responsible Consumption and Production), particularly Target 12.8, which aims to ensure people have the relevant information and awareness for sustainable development and lifestyles. This report synthesizes the findings, highlighting the significant gap between corporate marketing and genuine contributions to the 2030 Agenda.

Key Findings: A Disconnect in Corporate Accountability for Sustainable Development

The study reveals a significant disconnect between corporate sustainability messaging and verifiable practices. While 22% of the 8,800 products sampled featured environmental claims, a concerning 62% of these failed to comply with at least two core principles of the Green Claims Code. This widespread non-compliance indicates a systemic failure in providing the transparent and reliable sustainability information mandated by SDG Target 12.6, which encourages companies to adopt sustainable practices and integrate sustainability information into their reporting cycles. The sectors demonstrating the highest risk of non-compliance were cleaning products, electronics, and personal care, indicating areas where progress towards SDG 12 is most urgently needed.

Framework for SDG Alignment

The analysis was based on five principles derived from the Green Claims Code, which function as essential criteria for authentic corporate engagement with the SDGs:

1. Claims must be truthful and accurate.
2. Claims must be clear and unambiguous to empower consumer choice.
3. Comparative claims must be fair and meaningful.
4. Claims must be substantiated with credible evidence.
5. Claims must consider the full lifecycle of the product, reflecting a holistic approach to sustainability.

Case Study Analysis: Misalignment with SDG Principles

The following case studies from the report illustrate how misleading environmental claims undermine specific Sustainable Development Goals.

Example 1: Delphis Floor Cleaner

The product’s claim of being “made from highly biodegradable, renewable and sustainable ingredients” was presented without substantiation. This practice directly contravenes the principles of SDG 12 by providing vague assurances rather than clear, evidence-based information on the sustainable management of natural resources (Target 12.2).

• Clarity and Ambiguity: The general nature of the claim fails to provide consumers with specific information to make a responsible choice.
• Substantiation: The absence of supporting evidence or links to further information prevents verification and accountability.

Example 2: KIT & KIN Hypoallergenic Eco Nappy Pants

This product featured multiple claims that obscure rather than clarify its environmental impact. The use of unexplained technical terms and unsubstantiated claims like “carbon neutral factory” misleads consumers and detracts from genuine efforts to achieve SDG 13 (Climate Action) and SDG 12.

• Clarity and Ambiguity: Technical terms such as “oxo-biodegradable material” are not accessible to the average consumer, undermining Target 12.8.
• Fair Comparisons: The claim of being the “most accredited eco nappy” was not verifiable.
• Substantiation: The “carbon neutral” claim lacked accessible evidence, a critical component for corporate climate accountability under SDG 13.

Example 3: Seasalt Cornwall Men’s Blazer

The description of a blazer as “organic” without recognized certification or details on the material composition fails to support sustainable agriculture and production systems as envisioned in SDG 15 (Life on Land) and SDG 12. Unlike the food sector, where legal standards for “organic” claims are strict, the textile industry’s laxity allows for claims that may not reflect genuinely sustainable practices.

Example 4: Charlie Bingham Lasagne

A claim of using “30% less cardboard” was found to be non-compliant because it lacked a clear comparator. This ambiguity prevents consumers from assessing the claim’s significance in contributing to waste reduction, a key aspect of SDG 12.

Example 5: Kellogg’s Special K Cereal Bar

In contrast, Kellogg’s claim of using “less packaging” was deemed compliant and aligned with SDG 12 principles. The company provided a clear, verifiable, and substantiated comparison:

• It specified a 6.86% reduction compared to a previous pack.
• It included specific measurements as evidence.
• It provided a link to its website for full transparency.

Example 6: Adidas 7/8 Leggings

Adidas’s claim that its leggings were made with “85% recycled polyester” highlights a critical challenge in sustainability reporting: lifecycle consideration. By omitting the negative environmental impacts, such as microplastic shedding and non-biodegradability, the claim presents an incomplete picture. This selective disclosure undermines efforts to protect SDG 14 (Life Below Water) and SDG 6 (Clean Water and Sanitation) and fails the Code’s principle that the full environmental impact must be considered.

Recommendations for Aligning Marketing with the Sustainable Development Goals

To avoid regulatory action and contribute meaningfully to the 2030 Agenda, businesses must integrate the principles of the Green Claims Code into their marketing strategies. The following framework outlines key actions for ensuring claims are compliant and support the SDGs.

1. Ensure Truthfulness and Accuracy (Supports SDG 12, 15)
   • Validate all claims with robust, up-to-date evidence.
   • For “organic” claims, provide recognized certifications and specify the percentage of organic material.
2. Provide Clear Substantiation (Supports SDG 12.6)
   • Maintain a body of solid, objective evidence for every environmental claim.
   • Make supporting evidence easily accessible to consumers via links, QR codes, or clear references.
3. Maintain Clarity and Avoid Ambiguity (Supports SDG 12.8)
   • Replace vague, generic terms like “eco-friendly” or “sustainable” with specific, precise language detailing the environmental benefit.
   • Explain any necessary technical or scientific terms in language easily understood by the average consumer.
4. Conduct Fair and Meaningful Comparisons (Supports SDG 12)
   • Clearly identify the product or situation against which a comparison is being made.
   • Provide consumers with the information needed to independently verify the comparison.
5. Consider the Full Product Lifecycle (Supports SDG 12, 13, 14, 15)
   • Assess the total environmental impact of a product, from raw material extraction to end-of-life disposal.
   • Do not highlight a single positive attribute while omitting significant negative trade-offs, such as water usage, pollution, or non-biodegradability.

Analysis of Sustainable Development Goals in the Article

1. Which SDGs are addressed or connected to the issues highlighted in the article?

• SDG 12: Responsible Consumption and Production: This is the most central SDG addressed in the article. The entire text focuses on the relationship between producers (companies making environmental claims) and consumers. It critiques irresponsible production and marketing practices (greenwashing) and examines efforts to promote responsible consumption by ensuring consumers have accurate information. The analysis of the CMA’s Green Claims Code, which aims to make environmental claims “clear, accurate, and not misleading,” directly supports the goal of shifting towards sustainable patterns of consumption and production.
• SDG 16: Peace, Justice and Strong Institutions: The article highlights the role of a strong institution, the UK’s Competition and Markets Authority (CMA), in creating and enforcing rules for fair and transparent marketing. The establishment of the Green Claims Code and the legislative power of the Digital Markets, Competition and Consumers Act 2024 to issue fines are examples of effective, accountable, and transparent institutional mechanisms designed to combat misleading practices and protect consumer rights, which is a key aspect of this goal.

2. What specific targets under those SDGs can be identified based on the article’s content?

1. Target 12.6: Encourage companies, especially large and transnational companies, to adopt sustainable practices and to integrate sustainability information into their reporting cycle.
   • The article directly addresses this target by scrutinizing how companies integrate (or fail to integrate) sustainability information into their marketing and product descriptions. The case studies of Delphis, KIT & KIN, and Adidas exemplify failures in this area, as they provide unsubstantiated, unclear, or incomplete information. The CMA’s Code is presented as a tool to encourage companies to adopt more sustainable and transparent practices in their public communications.
2. Target 12.8: By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles in harmony with nature.
   • The core issue discussed, greenwashing, is a direct barrier to achieving this target. The article explains that vague claims (e.g., “sustainable ingredients”), unsubstantiated comparisons (e.g., “30% less cardboard”), and the omission of negative impacts prevent consumers from having the “relevant information” to make sustainable choices. The research finding that 62% of products with green claims were non-compliant underscores the scale of this information gap.
3. Target 16.6: Develop effective, accountable and transparent institutions at all levels.
   • The article showcases the CMA as an institution working to create accountability and transparency. By publishing the Green Claims Code and gaining enforcement powers through the Digital Markets, Competition and Consumers Act 2024, the CMA is developing an effective regulatory framework to hold businesses accountable for their environmental claims, thereby strengthening institutional capacity to ensure fair practices.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

• Indicator for Target 12.8: Percentage of products with non-compliant environmental claims.
  • The article provides a direct, quantifiable indicator from the London Economics report: “62% of products containing green claims failed tests relating to at least two of the principles” of the Code. This metric directly measures the prevalence of misleading information available to consumers and can be used to track progress in providing clear and accurate information over time.
• Indicator for Target 12.6: Rate of corporate compliance with principles for substantiated and transparent environmental claims.
  • The article implies several sub-indicators for measuring corporate adoption of sustainable practices in marketing. Progress could be measured by tracking:
    1. The percentage of claims that are substantiated with accessible evidence (e.g., the failure of Delphis vs. the success of Kellogg’s).
    2. The percentage of “organic” claims on non-food items that are backed by recognized certifications (as highlighted in the Seasalt Cornwall blazer example).
    3. The percentage of claims that consider the full product lifecycle, avoiding omissions of negative impacts (as seen in the Adidas leggings example).
• Indicator for Target 16.6: Existence and enforcement of national policies on greenwashing.
  • The article explicitly mentions the existence of such policies, which serve as an indicator of institutional strength. These include the “Competition and Markets Authority’s (CMA) Green Claims Code” and the “Digital Markets, Competition and Consumers Act 2024,” which gives the CMA the power to issue fines. The enforcement of these regulations (e.g., number of investigations or fines issued) would be a further indicator of institutional effectiveness.

4. Create a table with three columns titled ‘SDGs, Targets and Indicators” to present the findings from analyzing the article. In this table, list the Sustainable Development Goals (SDGs), their corresponding targets, and the specific indicators identified in the article.

Source: natlawreview.com