Executive summary
An environmental claim needs to be accurate, clearly explained and supported before it is used. A supplier’s statement can become your claim when you repeat it in a catalogue, online listing or customer communication. The Competition and Markets Authority’s January 2026 guidance explains supply-chain responsibilities where claims can affect consumers.[1] Construction businesses should also check the rules for business-to-business advertising.[2] Keep each claim tied to the relevant product or company, its assessment boundary and current evidence, with a clear approval owner.
Start here
List the environmental claims on your five most prominent product pages and record the evidence supporting each exact wording.
In plain terms
A claim is more than a sentence. A badge, photograph or missing qualification can change what a buyer understands. “Lower manufacturing emissions than our previous product” says something narrower than “sustainable”. The evidence and the overall impression need to support the same message.[1, 3]
Check the claim and its limits
| Claim type | Evidence and explanation to keep |
|---|---|
| Lower carbon | Named comparator, equivalent function, quantity, assessment method, stages and date. |
| Recycled content | Percentage, measurement basis, product or packaging scope and traceable supplier records. |
| Recyclable | Which parts, separation needs and whether an appropriate collection and processing route is available. |
| Carbon neutral or net zero | Boundary, period, reductions and any reliance on offsets; explain what the claim actually covers.[4] |
Different audiences bring different rules
The CMA’s consumer guidance covers supply-chain claims capable of influencing consumers, including information passed through intermediaries. Purely business-to-business practices with no potential consumer effect need a separate assessment under the Business Protection from Misleading Marketing Regulations 2008.[1, 2] The UK non-broadcast advertising code also contains specific rules on environmental claims.[3]
An Environmental Product Declaration (EPD) reports assessed product impacts; its existence alone does not establish that a product is environmentally preferable. Apply the relevant comparison method and disclose limitations. A manufacturing-stage result must not suggest a whole-life benefit unless that broader conclusion is supported.[3]
Recommended actions
Suggested owners, timing and evidence for the next steps:
Inventory the claims
Capture exact wording, images, channel, product and intended audience. Prioritise prominent or absolute claims and those used across many distributor pages; keep a dated list.
Marketing lead, before the next campaign
Build the evidence file
Match claims to current evidence, assessment boundaries and product coverage. If a supplier cannot substantiate a claim, consider narrowing or withdrawing it. Keep the basis for the approved wording.[1]
Technical and reporting leads, before approval
Check the comparator
Confirm equivalent performance and assessment conditions. Explain the baseline and what changed. Keep the calculation and supporting method rather than publishing an unexplained percentage reduction.
Commercial lead, before comparison
Approve the complete presentation
Read the wording and qualifications together as a buyer would. Obtain legal or specialist review for material uncertainty; keep the approved version and instructions for third parties.
Authorised reviewer, before release
Update or withdraw
Link evidence expiry and product changes to a review task. Correct outdated listings and distributor copy, keeping a record of who was notified and which statements were replaced.
Product owner, at each change
Example in practice
Illustrative example: comparable assessments show 100 and 80 kilograms of carbon dioxide equivalent per equivalent product unit for the same manufacturing stages. This is a 20% reduction for those stages, subject to the method and evidence. It does not establish a 20% reduction over the building’s whole life.
Common mistakes
How Reinventives can help
Reinventives can review the data behind product and company claims, organise an evidence register and establish approval and renewal checks. The first output can be a prioritised claim-and-evidence review for a product range. We can coordinate qualified assessment or legal specialists where technical comparisons or advertising judgements require their input.
Sources and review dates
- 1.CMA, Making green claims across the supply chain, 22 January 2026; scope, liability and evidence.
- 2.CMA, Unfair commercial practices, CMA207, November 2025; business-to-business practices.
- 3.ASA / CAP, Non-broadcast Code, section 11, Environmental claims, rules 11.1-11.4.
- 4.ASA / CAP, Carbon offsetting and carbon neutral, 17 June 2026; qualifications and offsets.
Sources accessed and correct as of 9 September 2026.
Next scheduled review 9 December 2026.
Review earlier when the CMA or ASA changes guidance, or a product, comparator or supporting assessment changes.
This briefing is general information, not legal, procurement, engineering or assurance advice. Requirements should be checked for the specific organisation, project and contract.