According to 2024 research from Amazon UK, two in three British shoppers (66%) would prefer to buy products that have a more positive environmental and social impact. As the environment becomes more important on consumers' lists, it's no surprise that more brands are looking into their sustainability records and green credentials to see how they can make these a selling point. For some companies, being green is the entire foundation of their brand. But this comes with risk – overstating those green claims, to the point of exaggeration or false claims. This is what's known as greenwashing – when businesses overstate their good environmental credentials (either purposefully or not).
In this post, we take you through what greenwashing is, how to avoid greenwashing in your marketing copy, and how to stay on the right side of new regulations like the 2024 Digital Markets, Competition and Consumers (DMCC) Act that have come in to make sure brands are always on the right side of the law.
What is greenwashing?
Sustainability sells. If a brand looks like it's doing its bit for the environment and taking the lead, more people generally want to buy it. Sloppy sustainability claims can however be a brand's undoing. The problem with greenwashing is that rather than communicating genuine progress, some brands tend to say things with vague phrasing, overly-broad headlines and glossy nature visuals that imply more than the facts support.
In the UK, greenwashing isn’t just a reputational risk – it's an increasingly regulatory one. The Competition and Markets Authority’s Green Claims Code sets out how to stay on the right side of the law. The Advertising Standards Authority applies strict ad rules, the Financial Conduct Authority now enforces an anti-greenwashing rule for financial firms, and the Digital Markets, Competition and Consumers Act 2024 (DMCC) gives the CMA power to impose serious fines if green claims can't be backed up with evidence. This is why it's so important to write marketing copy that is persuasive, precise and compliant.
What “greenwashing” really means in practice
Greenwashing is any communication that misleads people about the environmental impact of a product, service or organisation. It can be overt, such as declaring something “100% sustainable” without evidence, or it can be very subtle, such as focusing on a small positive initiative while omitting a negative impact.
The ASA’s ruling against HSBC in 2022 is a clear example of greenwashing ads that were banned. The ads in question highlighted green finance and tree-planting, but were banned because they omitted significant information about the bank’s ongoing financing of non-environmentally friendly emissions-based activities, leaving consumers with a distorted impression of the company’s overall green impact. The regulator held that making these unqualified claims risked being misleading by omitting context.
Greenwashing and the law
To ensure consumers are protected from baseless claims, the CMA’s Green Claims Code states that brands must make their claims:
- Truthful and accurate.
- Clear and unambiguous.
- Open and honest, without hiding important information.
- Fair, with meaningful comparisons and strong evidence.
When it comes to the ASA’s CAP Code, Section 11 on environmental claims states that absolute claims such as “zero emissions” or “climate neutral” must be backed by a high level of substantiation. Brands should base their environmental claims on the full product life cycle unless the ad clearly says otherwise. Carbon-neutral or offsetting claims must also be specific about scope, method and residual impacts.
If you are in or adjacent to financial services, you must also align with the FCA’s anti-greenwashing rule. Since 31 May 2024, any sustainability reference made to consumers must be fair, clear and not misleading, and proportionate to the true sustainability profile of the product or service. The guidance is explicit about clarity, evidence and the risk of exaggeration. In other words, the copy has to live up to the claim.
Then there's the DMCC Act, which ensures that the CMA can issue direct fines for consumer-law breaches, including misleading environmental claims, with potential penalties of up to 10% of global turnover.
Writing sustainability claims without being misleading or greenwashing
Back claims with evidence
As your agency partner, our advice always begins with evidence. Claims should be built from accurate data and, where relevant, third-party certifications. If your packaging contains 80% post-consumer recycled paper certified by the FSC, you should say say precisely that. Avoid the temptation to make sweeping claims like: “planet-friendly packaging” without context. The Green Claims Code expects brands to be able to back up their claims, not promise to backfill proofs later.
Be honest about your brand's progress
If your brand's green progress is partial, describe it candidly. “We’ve reduced Scope 2 emissions by 35% since 2022 through a switch to renewable electricity”. Taking this approach is far more trustworthy than a sweeping “we’re carbon neutral” line that relies solely on offsets and leaves out major categories of emissions. The ASA has repeatedly ruled that unqualified or absolute claims require a high standard of proof and a life-cycle perspective.
Give context
Context is your friend. If you want to showcase a positive green change that your brand has made, set expectations by explaining what part of the business it covers and what still needs to be done. If you're a retailer launching a fashion collection made with recycled fibres, explain the percentage content, the certification standard, the range affected and the plan to extend those practices across the wider business. Generic “eco” or “sustainable” labels, green icons and broad claims are out.
Be cautious with 'green' environmental imagery and language
Avoid implication by imagery. Designers love verdant colour palettes, leaf motifs and misty forests, but if your business has not addressed material sustainability impacts, those cues can mislead. If you use terms like “carbon neutral” or “climate positive,” the ASA expects clarity about whether reductions have actually been achieved or whether residual emissions are being offset, and how.
The problem of Greenhushing
Fear of criticism has driven some brands into “greenhushing,” where they say nothing at all about the environmental side of their business. Greenhushing is becoming increasingly common as brands grow wary of public backlash, yet silence can be just as damaging as exaggeration. It can be interpreted as evasiveness or a lack of meaningful action. This can backfire with investors, employees and customers who expect visibility on climate and nature impacts. Rather than staying quiet, brands should be open, honest and publish clear messaging on their sustainability credentials. They should discuss what's been achieved so far, what hasn't, and what targets come next. The Green Claims Code explicitly encourages full-story communication and warns against cherry-picking. Honest storytelling, even about imperfect progress, builds credibility. Silence, by contrast, creates mistrust.
The takeaway
We get it – many brands want copy that makes their brand truly sparkle – especially if their green credentials are a cut above others in their sector. It's possible to make the most of green achievements in copy while making it persuasive in terms of marketing. Remember that when it comes to climate and sustainability claims, the best copy that sells is honest. Aligning your claims with the CMA’s/DMCC's principles, ASA’s life-cycle and substantiation rules, and the FCA’s fairness and clarity standard will help your brand speak clearly and confidently.
