Which law applies
There is no dedicated green labelling regime for food in the way there is for organic production or for nutrition and health claims. Environmental claims on food are governed by the general law on unfair commercial practices, by the requirement that food information must not be misleading, and by the advertising codes.
That general law is now found principally in the Digital Markets, Competition and Consumers Act 2024, which replaced the previous consumer protection regulations for unfair commercial practices and gave the Competition and Markets Authority direct enforcement powers rather than requiring it to go to court.
The practical effect is a change in enforcement risk rather than in the underlying standard. A misleading environmental claim was already unlawful. What changed is who can act on it and how quickly.
The Green Claims Code
The CMA published the Green Claims Code to set out how businesses should apply consumer protection law to environmental claims. It is guidance rather than legislation, and it is built around six principles.
- Claims must be truthful and accurate.
- Claims must be clear and unambiguous.
- Claims must not omit or hide important information.
- Comparisons must be fair and meaningful.
- Claims must consider the full life cycle of the product.
- Claims must be substantiated.
Several of these bite particularly hard on food. The full life cycle principle matters because food has a complex footprint spread across agriculture, processing, packaging, distribution and waste, and a claim about one stage can create an impression about the whole. The completeness principle matters because packaging claims are often true of one component of a pack and not of the others.
| Principle | Where it bites hardest on food |
|---|---|
| Truthful and accurate | Production method wording that overstates what a farm actually does |
| Clear and unambiguous | Claims that could refer to the food or to the packaging |
| Does not omit or hide important information | Recyclability without local collection context |
| Comparisons are fair and meaningful | Percentage improvements with an unstated baseline |
| Considers the full life cycle | Packaging claims that imply something about the food |
| Substantiated | Carbon figures without a stated method or boundary |
Structure set out by this newsroom from the published rules named in the sources below. It is not a survey, a measurement or a market study.
Packaging claims, which are the most common
The largest group of environmental claims on food concerns the packaging rather than the food. Recyclability, recycled content, compostability and biodegradability are the recurring themes.
Each raises the same structural issue: the claim is true only under conditions that the shopper may not be able to meet. Recyclability depends on local collection arrangements. Compostability frequently means industrially compostable, which is a different process from a garden compost heap. Recycled content is a claim about inputs and says nothing about what happens next.
The completeness principle addresses exactly this. Where a qualification is needed to prevent a false impression, it needs to be given with the claim rather than buried, and prominence matters. A claim in large type with its condition in small type is the pattern the guidance is written against.
A related issue is component claims. Where a pack is made of several materials, a claim about one part can read as a claim about all of it. Guidance on how a claim is presented has to deal with which part of the pack it applies to.
Carbon and neutrality claims
Claims about carbon are the hardest category, because they rely on methodology that is invisible to the reader.
A footprint figure depends on system boundaries, on allocation choices between co-products, on which emissions are counted, and on the data used. Two figures produced by different methods are not comparable, and the number itself carries none of that context.
Neutrality claims add a further layer, because they typically depend on offsetting, and the quality and permanence of offsets vary. The CMA has been explicit that claims of this kind require particular care, that the basis must be clear, and that vague terms are a risk.
Where a standardised method exists, it is worth knowing about. Publicly available specifications for product carbon footprinting set out how a life cycle assessment should be conducted, and international standards address the same territory. A claim referencing a named method is a materially stronger claim than a bare figure.
Claims about how the food was produced
Beyond packaging, environmental claims about production are increasingly common: wording about soil, biodiversity, regenerative practice, water use and farming method.
Almost none of these terms has a legal definition. Some are covered by certification schemes with published standards, which is where a checkable meaning lives. Most are not, and are governed by the same general rules as any other undefined pack wording.
The distinction is exactly the one this publication returns to constantly. A term backed by a scheme with a published standard and an audit is testable. A term describing an aspiration is not, however sincerely meant.
How to read a green claim
Three questions do most of the work.
What exactly does the claim apply to? The food, the packaging, one component of the packaging, or the business as a whole. These are routinely conflated and are entirely different assertions.
What condition does it depend on? Recyclability depends on collection, compostability on facilities, offsets on the offset. If the condition is not stated, the claim is incomplete on the guidance's own terms.
Is there a named standard or scheme? A reference to a published specification, a certification body or an accredited scheme is the difference between a claim that can be checked and one that cannot.
What this article does not do
This is a description of how environmental claims are regulated. It is not an assessment of any product, any packaging format or any farming method, and it makes no environmental recommendation. Where the environmental questions become technical, the standards bodies and the CMA guidance are the sources, not a consumer title.