Green claims on UK packaging and unboxing under ASA and CMA rules

What to take away

What the ASA non-broadcast code permits on packaging

The ASA non-broadcast code permits environmental claims on packaging only when they are substantiated, clear and not misleading. The relevant rules sit in the CAP Code, which the ASA applies to non-broadcast ads, including pack copy and brand-owned digital content. You can read the full rule set in the Non-broadcast Code - ASA | CAP.

Packaging counts as advertising when it promotes a product, a brand or a commercial idea. A cereal box that says "100% recyclable" is making an ad claim, even though the box is also a physical container. The same words in a shelf-edge leaflet or a QR-linked landing page fall under the same rules.

The ASA expects claims to be interpreted as the average consumer would read them. That means a claim in large type on the front of a pack cannot be corrected by small print on the back. If the qualification changes the meaning, it belongs next to the claim.

The code also covers comparisons. A claim that a pack is "greener than" another product must compare like with like and must not imply a total environmental advantage when the benefit is narrow. A recycled-content claim, for example, does not support a broader "eco-friendly" badge.

Packaging claims interact with waste and labelling law as well as advertising law. The The Packaging (Essential Requirements) Regulations 2015 set essential requirements on packaging weight, volume and recoverability. A claim that a pack is recyclable must sit comfortably with those requirements and with what local collection actually accepts.

For food packs, claims also sit alongside food labelling rules. The Packaging and labelling: legal requirements for food businesses - GOV.UK page sets out what food businesses must show on packs, including information that cannot be displaced by marketing copy. Green claims must not obscure mandatory information or contradict it.

Enforcement is complaint-led. The ASA publishes rulings and asks advertisers to change or withdraw claims. It cannot fine, but non-compliance leads to adverse publicity and, for some advertisers, referral to trading standards. That risk is why UK marketing teams treat pack copy as regulated advertising, not decoration.

Where the code stops

The code does not ban environmental claims. It bans unproven ones. A claim that is specific, evidenced and qualified can run on a pack for years. The test is whether the evidence existed when the claim was made and whether the wording matches the evidence.

What the CMA green claims guidance requires of businesses

The CMA green claims guidance requires businesses to make environmental claims that are truthful, clear, complete and substantiated. The Competition and Markets Authority enforces consumer protection law, including the Digital Markets, Competition and Consumers Act regime, and its guidance applies to packaging, websites, ads and social content.

The guidance sets six principles. Claims must be truthful and accurate. They must be clear and unambiguous. They must not omit or hide important information. Comparisons must be fair and meaningful. The full life cycle of the product or service must be considered. And claims must be substantiated with evidence.

For packaging, the life cycle point bites hardest. A pack that says "sustainable" implies a whole-life benefit. If only the ink is vegetable-based, the claim is not supported. A narrower claim, such as "printed with vegetable-based inks", is supported by that same fact.

The CMA expects businesses to hold evidence before making a claim, not to gather it after a complaint. Evidence should cover the specific attribute claimed, the period it covers and the parts of the life cycle it excludes. If a claim excludes packaging, say so.

The CMA can investigate misleading green claims, accept undertakings and, where needed, take court action. It has published guidance for businesses and has run reviews in sectors such as fashion, travel and fast moving consumer goods. Packaging claims sit inside those reviews whenever the pack carries the claim.

Consumer law and advertising codes overlap. A claim that breaches the CAP Code may also breach consumer protection law. UK compliance teams therefore map each claim to both regimes before sign-off. That dual check is the practical meaning of ASA CMA green claims packaging compliance.

For teams writing pack copy in England, Scotland, Wales and Northern Ireland, the same consumer law applies. Packaging producer responsibility differs, sitting with the Environment Agency, SEPA, Natural Resources Wales and the NIEA.

DEFRA sets the packaging waste policy framework, and HMRC collects Plastic Packaging Tax on packs with less than 30% recycled plastic. A recycled-content claim must match both the tax position and the evidence file.

The evidence file

Keep a claim file per SKU. It should hold the evidence, the exact wording approved, the date of approval and the person who signed it off. If the wording changes, the file changes. This is the record the CMA or the ASA will ask for.

Wording that fails: vague and unqualified environmental claims

Vague and unqualified environmental claims fail because they cannot be verified. Words such as eco-friendly, green, sustainable, environmentally friendly and nature's choice carry no fixed meaning. The ASA has upheld complaints against each of these when the advertiser could not show a whole-life benefit.

The following table sets out wording that commonly fails, with the reason.

Failing wording	Why it fails

Absolutes are the most common failure. "100% recyclable" is only safe if every component, including caps, labels and adhesives, is accepted in kerbside collection across the market where the pack is sold. In practice, that is rare, so qualified wording is safer.

Omission is the second common failure. A pack that is recyclable but shipped in a non-recyclable mailer, or sold with a plastic sleeve, invites a complaint if the claim implies the whole delivery is recyclable. The average consumer reads the claim as covering what arrives.

Imagery counts as a claim. A leaf motif, a green tick or a globe on a pack can imply an environmental benefit even without words. The ASA treats such imagery as part of the overall impression, so it must be capable of substantiation.

Wording that passes: specific, evidenced and comparative claims

Specific, evidenced and comparative claims pass because a reader can check them. The safest wording names the attribute, the scope and, where relevant, the comparator. It avoids absolutes unless the evidence covers every component and every market.

Passing wording tends to follow a pattern: attribute plus scope plus evidence. "Bottle made from 100% recycled PET, excluding cap and label" is specific, bounded and checkable. "Packaging is recyclable in kerbside collections across the UK; check locally" is qualified and honest.

Comparative claims pass when the comparator is named and the metric is clear. "This pack uses 30% less plastic than our previous pack" works if the baseline pack is identified and the measurement is documented. "Greener than the leading brand" does not, because the metric and the evidence are missing.

Carbon claims pass when the scope is stated. "Carbon footprint of this pack measured from cradle to gate, verified in 2025" tells the reader what is included and what is not. It also signals that offsets are not being used to claim neutrality.

Recycled content claims pass when they match the tax and regulatory position. Under Plastic Packaging Tax, packs with less than 30% recycled plastic attract the tax, so a claim of high recycled content should match the recorded composition. The claim and the tax return should tell the same story.

Worked example: rewriting a failing pack

A UK drinks brand prints "Eco-friendly bottle, 100% green" on a PET bottle with a plastic cap and a paper label. A complaint is likely to succeed because the claim is vague and absolute.

The rewritten pack passes because each word can be checked. It also survives scrutiny from trading standards and from a consumer complaint. If the wording later changes, your packaging marketing disclosure policy should be updated so the approved claim and the evidence file stay in step.

Green claims in unboxing videos and creator content

Unboxing video claims fall under the same rules as pack copy when the video is an ad. That happens when the creator is paid, gifted or otherwise incentivised. The ASA has ruled against influencer content that made environmental claims without evidence, and the CMA guidance applies to social content as it does to packs.

A creator who says "this packaging is fully compostable" is making an ad claim. If the pack is only industrially compostable and no industrial facility is available to the viewer, the claim misleads. The brand that briefed the creator shares responsibility.

Brief creators with approved wording. Give them the claim, the qualification and the evidence summary. Do not let them improvise environmental claims on camera. The safest scripts use the same words as the pack.

Disclosure matters too. A paid partnership must be labelled clearly. An ad that hides the commercial relationship and makes green claims compounds the problem. The ASA treats both issues in the same ruling.

Video adds a risk that print does not: the pack is shown in close-up, so every on-pack claim is repeated on screen. A claim that was borderline in small print becomes prominent in a 4K unboxing shot. Audit the pack before you brief the creator.

Platforms vary in how they label paid content, but the underlying rules do not. A TikTok unboxing, a YouTube review and an Instagram reel all fall under the CAP Code when they are ads. The packaging marketing advertising rules checks apply to each format.

Creator brief checklist

Substantiating claims before you print or publish

Substantiation is the evidence that a claim is true. For packaging, it must exist before the artwork is signed off. A claim made first and evidenced later is a breach, even if the evidence arrives before a complaint.

The evidence must cover the attribute claimed and the life cycle implied. A recyclability claim needs evidence on material, collection infrastructure and the market where the pack is sold. A recycled-content claim needs supplier certificates and composition records. A carbon claim needs a methodology, a boundary and a period.

Evidence should be current. A study from several years ago may not reflect the current pack, supplier or collection system. Date every document and review claims when the pack, supplier or market changes.

Keep the evidence proportionate. A minor claim needs less evidence than a headline claim, but every claim needs some. If the evidence is thin, narrow the claim until it is solid.

Internal sign-off should include marketing, packaging, legal and, where relevant, sustainability. One owner should hold the claim file. When a claim is retired, record why and when.

Regulators may ask for evidence months or years after publication. A file that cannot be produced is treated as if the evidence does not exist. That is why the file, not the memory, is the control.

Claims that need extra care

Carbon neutral, net zero, plastic-free, compostable and biodegradable need extra care. Each implies a whole-life or end-of-life outcome that depends on infrastructure the brand may not control. Qualify them or avoid them.

Due diligence using published ASA rulings

Published ASA rulings are free due diligence. They show how the regulator has treated wording similar to yours, and they name the evidence that was missing. Reading the rulings in your category before sign-off is faster than learning from a complaint.

The Rulings - ASA | CAP page holds the full archive. Search by keyword, sector or advertiser. Build a short list of rulings that touch your claims, then test your wording against them.

Use rulings as a red-team exercise. Ask a colleague to find a ruling that could be used against your pack. If they can, rewrite the claim. If they cannot, the claim is more likely to hold.

Rulings also show the limits of qualifications. Small print that contradicts the headline claim has failed before. The fix is to change the headline, not to add more small print.

Record your review. Note the rulings you checked, the date and the changes made. That record supports a due diligence defence and shows the claim was considered, not copied.

The same rulings apply to teams in Greater London, the West Midlands, Greater Manchester, West Yorkshire and Scotland. Teams in Wales, Northern Ireland and the rest of the UK work to the same code, because consumer law is national.

A simple review routine

This routine fits inside a normal artwork approval. It also links packaging claims to the wider packaging marketing rules and ethics that govern UK pack copy.

Common questions