Avoiding greenwashing through credible communications

As business owners or employees, we understand the importance of engaging with the environmental agenda and delivering products and services that either minimise harm to, or have a positive effect on, the environment. 

We also understand that claims made about the environmental credentials of goods and services have an important influence over consumer decisions. Consumers are known to be drawn to sustainably sourced goods and are very often willing to pay a premium for these products (PWC Global Consumer Insights Pulse Survey, 2023). 

For several years there have been concerns about the prevalence of misleading green claims in the marketing of goods and services alike, a practice known as greenwashing. A study conducted by Which? and London Economics last year provided further insight into the extent of this issue, finding that only 16% of product sampled passed all their checks against principles designed to ensure that green claims are re clear, accurate and not misleading (Which?, How green are green claims?).

Whether intentional or otherwise, organisations are getting it wrong. During a recent webinar hosted by edie, we explored the risks that this brings. In 2025 the UK saw new and robust legislation, a greater regulatory focus driven by sophisticated AI-assisted monitoring and enforcement, new avenues for public and private litigation, and growing social awareness of sustainability corporate sustainability credentials, which lead to increased risks for those making misleading claims.

Business objectives for 2026 should be the same as they have been in previous years – to avoid accusations of greenwashing through transparent communications. In navigating these risks, we also unlock the opportunities to be gained through meaningful engagement with sustainability agenda in the marketing of your goods and services.

We apply learnings from 2025 to ask the question – what does good look like in this area and how do you become great?

Looking good

The starting point for any business making environmental claims on goods or services in the UK should be the Competition and Market Authority’s (CMA) Green Claims Code (the Code). The Code introduced six principles to help businesses comply with consumer protection law in the UK and, in doing so, protect consumers from misleading environmental claims. Claims must:

• be truthful and accurate
• be clear and unambiguous
• not omit or hide important relevant information
• must be fair and meaningful
• consider the full life cycle of the product or service
• must be substantiated

Uncontentious as a set of principles, the Code provided guidance as to what each of the above means, questions to prompt compliance and worked examples to guide implementation. It was an important and welcome milestone in regulation of environmental claims. 

Celebrating its fifth birthday this year, the Code has aged well. It has also benefitted from a wealth of guidance that has followed, from the CMA and others. Although not a statutory regulator, the contribution of the Advertising Standards Authority (ASA), particularly through the work of its Climate Change and the Environment (CCE) project, has been immense. The CCE project has included sector specific reviews, targeted investigations and research into consumer understanding of claims. In October 2025 the ASA reissued its consolidated guidance, Misleading environmental claims and social responsibility in advertising, a must read for anyone involved in the making of green claims.

Singling out one of the many useful resources in this area, research commissioned by the ASA in 2022, looks at consumer understanding of environment-based terminology used in ads, focusing on Carbon Neutral and Net Zero claims. To this day, this is a particularly useful tool when thinking about what good looks like. 

How to look great

Looking great requires further work. Vanity aside, the incentives for doing so are compelling:

• Greater consumer impact
• Confidence in aligning environmental claims with wider sustainability commitments and initiatives
• Reduced risk of complaints (consumer, competitor, regulator)
• Future proof against increasing regulatory/third party scrutiny

Working with clients from several different sectors and industries, our top tips are:

1. Don’t look at a claim in isolation

A common misconception is the belief that a factually accurate claim cannot mislead. Regulators and Courts have consistently confirmed that this is not the case. The ASA ruling in HSBC UK Bank plc (2022) is a useful reference point. By omitting crucial information about the bank's continued funding of fossil fuels and high-emission industries, unqualified claims made by HSBC about its environmentally beneficial work were found by the ASA to have misled consumers. 

Whilst the ASA were clear to dismiss claims of greenhushing following this and other similarly robust rulings, businesses operating in high emitting industries must take care when making environmental claims. More recent rulings in 2025 (Shell UK and Shell Energy ), along with additional guidance issued by the ASA, help plot a course through this difficult area but the key message is to take a wide view of claims being made.

2. Draw upon wider sustainability commitments

Claims that are built upon and reference a business’ wider sustainability strategy, commitments and initiatives have inherent credibility and reduce the risk of misleading consumers. For example, alignment with wider business sustainability disclosures (mandatory and voluntary) can provide an excellent basis to substantiate claims.

Coordination of marketing campaigns with these wider commitments supports credible, evidence-based, sustainability storytelling. 

3. Build upon a strong foundation of governance

A foundation of governance to support the making of claims can provide essential to providing confidence in respect of current and future claims.

• Design and implement company-wide policies & procedures for making claims – identify and assign roles and responsibilities to ensure that making environmental claims is not just be a marketing exercise. Commercial, sales, compliance and legal teams all play an important role.
• Substantiation & Verification – as part of these procedures, be clear on requirements for gathering and reviewing evidence for claims.
• Supply Chain – review due diligence arrangements on data from partners in the value chain where these inform your environmental claims.
• Audit – design a system for regular audit and periodic review of marketing materials.