The six principles, in plain English
The Competition and Markets Authority published the Green Claims Code in September 2021. It boils consumer law down to six principles:
| Principle | What it means for a small business |
|---|---|
| Truthful and accurate | The impression a claim gives must match reality, not just the literal words. A claim can be factually correct and still mislead. |
| Clear and unambiguous | Say what the claim covers: one product, one site, or the whole business. Explain technical terms next to the claim. |
| Don't omit or hide important information | Don't highlight a small green benefit while leaving out a big negative, or bury the qualifications. |
| Fair and meaningful comparisons | "30% less plastic" needs a clear "than what", measured the same way. |
| Consider the full life cycle | A product isn't "low carbon" if it is only low carbon at one stage. |
| Substantiated | Hold up-to-date evidence before you make the claim, not after someone complains. |
From April 2025 the legal duties behind the Code sit in the Digital Markets, Competition and Consumers Act 2024. The CMA can now decide for itself that the law has been broken and fine a business up to 10% of its global turnover. It says it takes a business's size into account when setting a fine, but there is no exemption for small firms.
Claims small firms commonly get wrong
- "Eco-friendly", "green" or "sustainable" on the homepage. The Code says these broad terms suggest your whole business has a positive or no environmental impact. Unless you can prove that, replace them with something specific: "our vans are electric" or "we repair before we replace".
- "Carbon neutral" or "net zero". The ASA's guidance says to avoid these unqualified, and to say whether a claim relies on offsetting. Our post on net zero target wording has safer phrasing.
- Repeating a supplier's claim. The CMA's January 2026 supply chain guidance says that when you stock and sell a product, you can be treated as making its claims too. If a "100% recycled" label turns out to be wrong, both the maker and the seller can be liable.
- "Recyclable" or "compostable". The Code says these often apply only to part of a product or in certain conditions, such as industrial composting, and that has to be explained.
- "Powered by 100% renewable electricity". Can be fine, but only with the full picture. See the worked example below.
A worked example: the renewable electricity claim
A shop and office use 25,000 kWh of electricity in 2026 on a renewable tariff backed by REGO certificates for the whole supply. Here is what the business's carbon figures say:
| Figure | tCO2e |
|---|---|
| Scope 2, location-based (UK grid average, 0.13096 kg CO2e per kWh) | 3.27 |
| Scope 2, market-based (REGO-backed tariff) | 0.00 |
| Scope 3: grid losses and producing the fuels for generation, which a tariff doesn't remove | 1.34 |
"Our electricity is supplied on a 100% renewable tariff" is a fair, specific claim. "Our shop has a zero carbon footprint" is not: the market-based Scope 2 figure is zero, but the location-based figure isn't, the Scope 3 parts remain, and electricity is only one part of the footprint. Our post on what REGOs actually buy explains why.
Selling to other businesses
The Code is written for claims to consumers, but the CMA says its examples generally apply where one business advertises to another, and misleading business-to-business marketing is covered by separate rules. What you write in tender answers and customer questionnaires counts too, so treat it the same way: specific, measured and dated. Our guide to answering a customer's carbon data request shows what to send.
A five-minute check of your own claims
- List every environmental word on your website, packaging, social media, proposals and email footer.
- For each, write down what it means in one sentence and what evidence you hold.
- Delete or rewrite anything you can't evidence today.
- Put qualifications next to the claim, or one click away, not on a separate page nobody finds.
- Diary a yearly review: tariffs change, suppliers change and products change.
How Carbon Recycling helps
The strongest green claim a small business can make is a measured one. Carbon Recycling turns your bills, fuel and travel records into Scope 1, 2 and 3 figures using the government's conversion factors for each year, and calculates location-based and market-based electricity from the same bills, so a renewable tariff claim and your actual footprint never get mixed up. Every figure records the factor behind it, which is the evidence the Code expects you to hold. To start, try the free kWh to CO2e calculator, or read our guide to offsets and green claims.