By Ben Thorne, Head of Sustainability, Jump Group
"Sustainability" is now central to how many brands communicate with customers. From recycled materials and lower-carbon products to reduced packaging, renewable energy, responsibly sourced ingredients, refill schemes, and more efficient delivery methods, businesses are increasingly highlighting the environmental progress they are making.
That is a positive development, provided the claims are accurate. The difficulty begins when marketing language outpaces the evidence behind it. A genuine improvement can quickly become misleading if it is described as “green”, “sustainable”, or “good for the planet” without enough context or substantiation.
This is the challenge of greenwashing: communicating environmental benefits in a way that creates a more positive impression than the facts support.
What Is Greenwashing?
A 2025 scoping review in the Journal of Sustainable Business highlights that greenwashing is a discrepancy between environmental communication and actual environmental practices, where organisations present themselves as greener than they are through vague or false information (Koch & Denner, 2025).
It can involve statements, imagery, labels, statistics, comparisons or omissions that give customers an inaccurate impression of environmental performance.
The Competition and Markets Authority, or CMA, describes misleading environmental claims as those that give the impression that a product, service, process, brand or business is less harmful or more beneficial to the environment than it really is. Importantly, the overall impression matters, including the words used, qualifications provided, imagery, logos, colours and information that may have been left out.
And greenwashing is not always deliberate.
In my experience, some of the biggest risks arise when there is a gap between sustainability teams, operational teams and marketing teams. Somebody knows that a new product contains more recycled material, uses less packaging, or has a lower carbon footprint, and somewhere along the line that perfectly legitimate improvement becomes described as “sustainable”, “green” or “good for the planet.”
The original information may have been correct. The final claim can still go too far.
What Does UK Regulation Say?
In the UK, businesses making environmental claims need to pay particular attention to the CMA’s Green Claims Code. The Code sets out six core principles designed to help businesses make environmental claims that comply with consumer protection law.
In simple terms, environmental claims should:
- Be truthful and accurate. A business needs to be able to deliver what the claim actually promises, without exaggerating the environmental benefit.
- Be clear and unambiguous. Customers should be able to understand what the claim means and what part of the product, service or business it relates to.
- Include important information. A technically accurate statement can still mislead if relevant context has been omitted or hidden.
- Make fair and meaningful comparisons. If something is described as having “30% less plastic”, for example, customers should be able to understand what it has 30% less plastic than.
- Consider the full life cycle where appropriate. A claim about one environmental benefit should not create a misleading impression about the environmental performance of the product as a whole.
- Be substantiated. Businesses should hold credible evidence supporting objective environmental claims before making them.
The advertising rules reinforce much of the same thinking. Under the CAP Code, which governs non-broadcast advertising, the basis of environmental claims must be clear, environmental terminology must be understandable to consumers, and absolute environmental claims require a high level of substantiation. Comparative claims such as “greener” must also make the basis of that comparison clear.
The consequences of getting this wrong have also become more significant. The consumer protection provisions of the Digital Markets, Competition and Consumers Act 2024 came into force on 6 April 2025, giving the CMA direct enforcement powers over unfair commercial practices. For breaches of consumer law, penalties can reach £300,000 or, where higher, up to 10% of worldwide turnover.
So this has moved well beyond an issue of brand reputation. Environmental communications increasingly need the same discipline around evidence and approval that businesses apply to other regulated claims.
Where Do Brands Commonly Go Wrong?
1. They Use Vague Environmental Language
One of the most common problems is vague environmental language. Words such as “green”, “sustainable”, “eco”, “planet friendly”, and “environmentally friendly” can imply a very broad environmental benefit, even when the underlying improvement is relatively specific.
Imagine that a company redesigns its plastic packaging and now uses 50% recycled materials. Simply saying “Now made with recycled plastic” is misleading. It may suggest that the packaging is entirely made from recycled plastic, when in reality only half of the material is recycled. It also leaves important questions unanswered: what type of plastic is used, how much of the packaging does the claim relate to, and is the material genuinely recycled or merely recyclable?
More accurate wording would be “This packaging contains 50% recycled plastic by weight”, assuming the evidence supports that. That statement tells customers exactly what has changed without implying a broader environmental benefit than the company can prove.
Calling the new packaging “sustainable packaging” is impossible to substantiate. In this scenario, sustainability covers far more than the quantity of recycled plastic involved.
2. They Publish Unsupported Statistics
Another common problem is the unsupported statistic. Claims such as “50% lower carbon”, “uses 40% less water”, or “three times greener” sound authoritative because they contain numbers, but the number alone tells us very little. What was measured? What is the baseline? What methodology was used? Does the figure refer to manufacturing, transport, the whole product life cycle, or something else entirely?
3. They Fall Into Selective Storytelling
A third problem is selective storytelling. A company might highlight that its packaging is recyclable while overlooking the fact that only part of it can realistically enter existing recycling streams, or promote renewable electricity at its offices while implying that the same applies across its manufacturing operations.
Each individual statement may contain an element of truth. The overall impression created for the customer still has to be accurate.
4. They Make Misleading Comparisons
Comparisons are another frequent source of trouble. Terms such as “greener”, “cleaner”, “lower impact”, or “better for the planet” require a meaningful point of comparison, and that comparison needs to be understandable to the customer.
How Can Brands Avoid Greenwashing?
The strongest approach is surprisingly straightforward: start with the evidence and build the communication from it.
If your evidence shows that packaging weight has fallen from 100g to 75g, you have the basis for a clear 25% reduction claim. If your carbon assessment shows that a particular product has a 15% lower cradle-to-gate footprint than its predecessor using the same methodology, say precisely that.
Accuracy and transparency are your friends.
The more ambitious the environmental claim, the stronger the evidence behind it needs to be. The ASA explicitly requires marketers to hold robust substantiation for objective environmental claims, while broader absolute claims can require evidence relating to the product’s full life cycle.
Brands should therefore create an evidence trail for the environmental claims they use. That might include carbon calculations, energy data, supplier declarations, certification documents, waste records, packaging specifications, life cycle assessments, or other credible supporting information.
Transparency matters too. If a claim only relates to one part of a product’s life cycle, say so. If a carbon reduction calculation covers manufacturing but excludes use and end of life, explain that boundary rather than allowing customers to assume the figure represents the whole product.
The same principle applies to comparisons. “30% less packaging than our 2024 design” gives the customer considerably more useful information than “30% less packaging.”
And finally, sustainability claims should have an internal review process. Marketing teams should know where the underlying data comes from, sustainability teams should understand how that information is being communicated, and somebody should be responsible for confirming that evidence remains current.
A claim that was accurate three years ago may no longer reflect the product, supply chain or methodology being used today.
A Simple Test Before Publishing An Environmental Claim
Before putting an environmental statement into the public domain, I would ask a few simple questions.
- Can we prove it? There should be credible evidence available today, rather than evidence that somebody hopes to obtain later.
- Is it specific? A customer should understand exactly what environmental benefit is being claimed.
- Is the scope clear? If the claim relates only to the packaging, manufacturing stage, UK operations or another defined boundary, make that clear.
- Is the comparison fair? The baseline should be relevant, consistent, and identifiable.
- Are we leaving anything important out? Consider whether additional context would materially change the way a reasonable customer interprets the claim.
- Would we be comfortable showing someone the calculation behind it? If the answer is no, there is probably more work to do before the claim becomes marketing copy.
Good Sustainability Communication Is About Precision
Sometimes there is a fear that increased scrutiny of green claims will make businesses reluctant to talk about sustainability at all. I think the better response is to become more precise about what we communicate.
If you have reduced your carbon footprint, tell people how much and from which baseline. If you have switched materials, explain what changed. If you have cut packaging, publish the numbers. If you have achieved an independently verified certification, state what has been certified.
Specific claims backed by credible evidence are more useful to customers and, in many cases, more compelling than sweeping environmental language anyway.
Brands don't need to present themselves as perfect to communicate sustainability effectively. Instead, they need to be able to demonstrate what they have achieved, acknowledge the limits of the evidence they have, and communicate both with clarity.
That is ultimately the best defence against greenwashing (and potential litigation), and a much stronger foundation for building trust with your customers.
