Green claims update

Key updates

The CMA issues new guidance on making green claims

• On 22 January 2026, the CMA issued new guidance, to be read in conjunction with its 2021 Green Claims Code, setting out how businesses can comply with consumer protection law when making environmental claims. The guidance clarifies how responsibility for such claims attaches to different businesses across the supply chain. The guidance also includes checklists for retailers, brands, suppliers and manufacturers setting out key points to consider when working with others in the supply chain to help ensure that green claims are not misleading.

Incoming EU legislation – Empowering Consumers for the Green Transition Directive (ECGTD)

• Key rules: prohibits vague or general environmental claims and unsubstantiated statements that a business or product is "green" or "environmentally friendly" and restricts the use of unreliable voluntary sustainability labels.
• Timing: entered into force in 2024. Member States must transpose the rules by 27 March 2026, with application from 27 September 2026.
• Guidance: the Commission recently published a Q&A providing further clarification on the ECGTD's anti-greenwashing provisions and how they will be applied.

ASA rulings

ASA ruling on Kit & Kin Ltd

• The ASA upheld Procter & Gamble UK's complaint that the advertised claims were misleading.
• Kit & Kin advertised “eco nappies wipes” with claims such as “PROTECTING YOUR WORLD, NATURALLY”, “better for our world”, “sustainable”, “made from sustainable, plant-based materials”, “biodegradable baby wipes" and "0% plastic”.
• The ASA found that “eco”, “better for our world” and “protecting your world, naturally” gave an overall impression that the products were environmentally beneficial or harmless across their life cycle, and that buying them protected the environment and rainforest. Kit & Kin’s certifications, carbon-neutral factory and charity partnership did not substantiate such broad, absolute environmental claims.
• The claims “sustainable” and “made from sustainable, plant-based materials” were treated as absolute sustainability claims about both the nappies and their materials. Kit & Kin had not provided full life cycle evidence, and the nappies still contained plastic components, so these claims were likely to mislead consumers.
• “Biodegradable baby wipes” was understood to mean the entire wipe would fully biodegrade in normal disposal conditions, more quickly than plastic alternatives and without harmful residue; the evidence only showed biodegradation of the viscose component under specific test conditions and did not address the whole product, real-world conditions, timeframes, or by-products.

• The ASA upheld the complaint in relation to all three issues, finding breaches of CAP Code rules on misleading and environmental claims and ruled that the ads must not appear again in their current form. Kit & Kin was told to clarify the basis of environmental and comparative claims and to hold robust, product-specific substantiation.

ASA ruling on The Cheeky Panda Ltd

• The ASA upheld a complaint made by Procter and Gamble UK that green claims made by Cheeky Panda's advertisements for "Bamboo Nappies" were misleading.
• Cheeky Panda’s website advertised nappies and baby wipes using claims such as “sustainable bamboo”, “100% sustainable bamboo fibre”, “biodegradable baby wipes/biodegradable fibres” and that the products were “kinder to the planet” and “protecting the planet”.
• On “sustainable bamboo" and "100% sustainable bamboo fibre”, the ASA found the claims were unqualified, absolute environmental claims requiring full life cycle evidence for the actual nappies and wipes. They found that Cheeky Panda’s life cycle analysis (LCA) and Forestry Stewardship Council (FSC) certification did not cover the whole product life cycle or the specific advertised products.
• On “biodegradable baby wipes" and "biodegradable fibres”, the ASA felt that consumers would expect the entire wipe to fully biodegrade in normal disposal conditions, leaving “no trace”. The evidence only showed partial biodegradation of the viscose fibre under specific conditions and did not substantiate the claims.
• On “kinder to the planet […] protecting the planet”, the ASA treated this as a comparative environmental claim implying that by containing bamboo, the nappies were less harmful than conventional nappies. The reports provided by Cheeky Panda did not show a clear environmental advantage or that the product “protected the planet”, so the claim was found to be also misleading.
• The ASA upheld all three issues, found breaches of the CAP Code on misleading and environmental claims, and ordered that the ads must not appear again in their current form. Cheeky Panda was told to clarify the basis of environmental claims and to hold robust substantiation in future.

Sector-specific updates

Food & Drink

The Guardian finds that Europe's supermarkets are filled with products misleadingly claimed to be packaged with recycled plastic.

• A recent report by The Guardian claims that "only a fraction" of the packaging materials used in Europe's supermarkets are recycled. Instead, it is claimed that most of the packaging is made from petroleum from Saudi Aramco, an oil company.
• Accused products include Kraft’s Heinz Beanz and Mondelēz’s Philadelphia.
• Read more here.

Coca-Cola introduces new paper-cardboard packaging

• Coca-Cola has introduced a corrugated paper-and-cardboard handle for multipacks of bottles in Europe. Coca-Cola has estimated that the change could reduce plastic waste by around 220 tonnes per year
• Read more here.

Spring 2026