The Green Claims Code - getting started today

The Green Claims Code - getting started and getting it right

What is the Green Claims Code?

At its most basic, the Green Claims Code (GCC) is a UK government mandated anti-greenwash guide for all and any brand making environmental claims. The 56 page guide was put together by the Competition and Markets Authority (CMA) - a non-ministerial government department - after studies suggested that up to 40% of ‘green’ claims globally could be misleading to consumers.

The aim of the GCC is to ensure that any claim made is truthful, accurate and can be corroborated by solid data/fact.

The CMA has given brands until the New Year 2022 to make sure that their environmental claims comply with the code.

What are “green claims”?

Also sometimes called ‘environmental claims’ or ‘eco-friendly claims’, ‘green claims’ are claims that show how a product, service, brand or even entire business provides a benefit or is less harmful to the environment.

There are myriad ways to make a claim to help market goods and services including statements, symbols, emblems, logos, graphics, colours, affiliations and product brand names. In short, anything that suggests an environmentally positive impact.

GCC Key takeaways

The guidance can be condensed down to 6 key principles:

1. Claims must be truthful and accurate

2. Claims must be clear and unambiguous

3. Claims must not omit or hide important information

4. Claims must only make fair and meaningful comparisons

5. Claims must consider the full life cycle of the product

6. Claims must be substantiated

Crucially, the GCC inextricably ties sustainability to marketing. It is no longer enough to leave compliance to your legal department because your marketing team will ultimately be responsible for the green claims you are publicly making.

For brands already engaged in meaningful, environmentally responsible practices, this is an exciting opportunity. Such a thorough, no-nonsense clampdown on greenwashing levels the playing field and gives legitimately ‘green’ businesses the chance to reap the commercial and reputational rewards. As Andrea Coscelli, chief executive of the CMA, says of the code: “...too many businesses are falsely taking credit for being green, while genuinely eco-friendly firms don’t get the recognition they deserve”.

In a sense this is your chance to get it right. The government has set out a very specific, rigorous framework of what best practice looks like and organisations who have been doing the work to mitigate their social and environmental impact, and who have the data to support their communications, have much to gain by telling the story of their products credibly.

A central aspect of the guidance is the sheer depth of information that brands will need to provide. For your sustainability credentials there is nowhere to hide and for your marketers there will be added pressure on your packaging and websites. Communicating sustainability effectively within the confines of your product packaging is impossible. The GCC specifically recommends QR codes as a means to share all the product’s sustainability credentials and if you plan to share sustainability content online, the GCC recommends that information is made available in a single click through link.

Terms like ‘green’, ‘sustainable’ or ‘eco-friendly,’ used without explanation, suggest that a product, service, process, brand or business as a whole has a positive environmental impact, or at least no adverse impact. This will no longer be permitted. Specificity will be key to anything you say; you’ll need to define what you mean by sustainable (for example) along with the specifics of what part of the product is sustainable and how. As the CMA’s Director of Consumer Protection Cecilia Parker Aranha says “ if a label says ‘Sustainably Sourced Fabric’ and only 5% of the fabric in the garment is sustainably sourced, that’s likely to be misleading and a problem from a consumer protection perspective.”

How to start immediately

Audit your existing claims - It’s vital to start with an audit of your existing claims. Palm-oil free, zero-waste, carbon neutral?? Double check what you’re saying is 100% accurate. Take special care when it comes to partial claims or ‘small wins’ - the CMA’s requirement to consider the entire lifecycle of products means brands who have until now overemphasised minor positives in their supply chains will need to think again.

Get your communications channels up to scratch - the amount of information you’re now required to share on a product will physically require a lot of text if you are to include all information that might inform a shopper’s purchase. All this simply won’t fit on a label, or be summed up in a snappy little logo. Per the GCC’s guidelines, you’ll need to use smart packaging (most likely QR codes) and website to hold all your publicly available information.

Marketing is now sustainability - companies and marketers need to commit fully to permanent integrity and can no longer leave compliance to their legal departments. Sustainability and data need to be a part of the marketer’s daily briefing.

Long term implications

Legal - The legal penalties for failing to comply with consumer protection laws are very real. If a business does not comply with these consumer protection law, the CMA can bring court proceedings, along with other bodies such as Trading Standards Services or the Advertising Standards Agency. Even consumers have the legal right to take action against those organisations they feel have breached the GCC’s requirements.

Organisational - Once you have completed your audit of existing claims and are moving to a longer term strategy, many businesses will need to bring their marketing and sustainability efforts together. Marketers can’t make claims about what they don’t know and delivering accurate, well founded claims depends on close collaboration between the two functions. The GCC is permanent legislation so this collaboration is not a one off project - work needs to be done as a team and developed to be long term, efficient and dynamic.

Authenticity - Concerns over greenwashing are at an all-time high when the need to shop more thoughtfully has never been greater - back to Cecilia Parker Aranha: “Trust in green claims is fragile and, unless brands provide the right information to consumers in the right way, there’s a risk that consumers will give up. That’s bad for green business, bad for consumers and bad for the planet.” In short, those companies approaching the GCC with a “ what can we get away with” attitude will soon find that the answer is “not a lot”.

Researching, proving and communicating your green credentials in a simple but comprehensive way will not only reconnect you to your existing customer/client base, but will connect you to a new set of potential consumers whilst burnishing your reputation as a genuine mover within a world of sustainable business.

At ESGmark® we welcome the GCC as an overdue way to inject some true momentum into business-driven sustainability. The choice for UK brands and business clearer than ever - rectify your claims to avoid CMA action and use the code as an opportunity to make conscious consumption a reality.

If you would like help with your own corporate/brand audit or would like to understand how ESGmark® can help you navigate this important subject with confidence, please contact us at info@esgmark.co.uk