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today's webinar, which is on green claims, maintaining compliant communications and avoiding regulatory pitfalls, which has been presented by our professional affiliate members Ashbury.
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First of all, thank you to everyone for coming today. We hope that you find the content useful.
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There will be a Q &A at the end, so please put any questions that you have into the questions box, and we'll do our best to go through as many as we can at the end of the webinar.
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Following the webinar today, we'll be sending you an article or email in the next couple of days, initial container recording of the webinar, a copy of the slides and the contact details of today's presenter. So without any further ado, I'll hand you over to today's presenter, Ed Allen.
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Thanks Luke. Good morning everyone.
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As Luke said, I'm Ed Allen, Head of Regulatory Affairs here at Ashbury.
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I've been in the food industry and consumer goods for just over 11 years now and green claims is probably one of those newer topics, although it's been around for a while, but I think the regulatory landscape is definitely changing, particularly around enforcement, so that's what I'm here today to talk to you about.
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Make sure you're ready to call your green claims in a compliant fashion. I'll start quickly, if you don't know us, we're Ashford Global.
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We founded in 2002 by our founder, James Post, who still leads us today.
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We specialise in multi-cash layering product compliance and also multi-country layering product compliance.
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We are the trusted compliance partner of many UK-leading retailers and manufacturers.
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We have over 125 experts in our team.
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We cover over 35 plus languages, which means we're well placed to deliver regulatory technical and training consultancy across 80 plus markets across the globe.
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For every business that's trying to achieve what I refer to as a unicorn of a globally compliant product.
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So we have global XLTs, we have offices across different regions, so our head offices are here in the UK and we have an office on the east coast of the USA and also an office in Australia.
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So as you know product labeling and compliance is essential bringing those new products to market.
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Food business operators and the regulatory landscape is just that complex maze of questions, queries, and things like that.
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So we deliver our projects on a global basis, but using a centralized service model.
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So you get that consistent service from us.
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So we're very proud to say that we've had over 200 ,000 approvals and without any labelling related product withdrawals or recalls.
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And so that kind of, we deliver services across a number of categories within kind of regulatory consultancy, technical services, international compliance and compliance training, regulatory consultancy from the regulatory advice right at the start of your product development process, and we'll come on to why that is key today when it comes to green claims, all the way through to instant management when the product's on the market and maybe something's gone wrong.
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We cover all the technical services in between including things like procedures and policies helping you develop those with our experts all the way through to training people on your new starters or your more seasoned experts within your teams on those new regulatory challenges that you're facing as a food business and help to develop those internal policies and procedures.
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So that's us as Ashbury and I'm here to talk to you about green claims but I'd like to start us with sustainability because sustainability does form kind of underpin those green claims and for those of you that have seen me present before, you'll likely recognise slide because I think it sums up sustainable products nicely.
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So sustainability banded around catch-all phrase but in reality it means nothing in isolation.
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So when we're considering products we need to consider those environmental, those economic and those social elements when it comes product production, because without considering all of those, we can't have a truly sustainable product. And as we know, sustainability is not a new theory or scientific discovery.
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It's been around for decades. The UN has defined it back in 1987.
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I'm sure there's plenty of definitions before then, but it is defined by the UN as meeting the needs of the present without compromising the ability of future generation to meet their own needs.
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I'm starting with this because when we consider products and or services, services will be key as we move through this.
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The first thought we always think about with green claims is what's the product's carbon footprint? What are the emissions?
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And that's probably where the consumer's mind goes to.
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Green claims span far beyond the carbon footprint of the product and truly green product will meet this UN definition.
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And that's why it's important to consider everything across your food system.
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So, the sustainable food system, we'll consider when making green claims, you'll be likely talking around, I've seen stuff around agriculture, so the things like soil health, biodiversity, water reduction.
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But sometimes we forget about those social elements, so your fair labour practices, community involvement, how is your business involved with the farming community that are producing those agricultural products and how is the industry itself training those farmers or providing them with the skills they need to develop a sustainable agricultural practices.
6:32
You'll also be looking and we'll touch on this later as well is sustainable packaging, recyclability, how can we produce food safe packaging that is recyclable or sustainable in the sense.
6:49
Water conservation is also a very key point when we're talking about farming and sustainable food systems.
6:55
What's quite shocking, surprising to me is that we often think about water conservation being a problem in countries that are hot, don't have much rain, drought, but actually UK is considered quite a wet country.
7:10
I know we've had our fair share of rain I think over the last couple of days or weeks, but we're actually facing water security issues in this country within decades to come.
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And so that's why when it comes to product development consumers are expecting that new and exciting product that's both affordable and sustainable and I think that we know sustainability or environmentally friendly practices, both claims that you shouldn't be using on pack, but making those affordable with the investment that is required to change processes across products is quite vast.
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And we also do need to consider consumers and their actions within this.
8:03
So we know developing a to spend costly from a financial and an environmental impact.
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But do we think about across the stage go process?
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Do we think about all the emissions that we're making or all of the environmental impacts we're having when we're making looking at that product development and want to make those product claims at the end?
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And with the food waste targets that come over the EU, how we consider that wastage associated with product trials, with the tasting, with the consumer acceptance testing, all of that.
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So we often think about footprint for an individual product, but we'd probably start to need to think about the overall journey of that product from planting it in the ground potentially all the way through to reaching the shelf and beyond.
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And that's where stakeholders across your supply chain are invaluable for helping you achieve your sustainability goals but also enabling you to make those green claims on your product at the end when your product is on shelf with the consumer.
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So it will become obvious as we start walking through this but stakeholders across the supply chain include people like agricultural partners due to their supporting role in the sustainable agriculture practice that we spoke about earlier, you've got your packaging partners, they help you develop new packaging materials that provide both food safety, shelf life, those types of things, but also need to support in building those materials that are recyclable or have other sustainable-related metrics or properties.
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Things like compostable, and we'll talk about that in terms of the requirements you have for their regulatory. Logistic partners, service providers.
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Logistic partners, we know moving products around. You may wish for them to be done in the most sustainable way.
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Also as well, we'll talk about the dynamic approach to your supply chain and then service providers will come onto this but often forget about services that have been provided into your business and what is the compliance of them and what have you considered everything there when you're looking at green your product.
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This diagram on the right hand side I think just shows you the two-way communication that needs to happen across all stakeholders to your business. And why is that important?
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Because globally there is increased accountability when it comes to being climate responsible.
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Global governments are asking more.
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This is just a selection, but they are holding businesses accountable for being climate responsible in their operations.
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We've seen things like the EU omnibus, packaging and product design and green claims directive from Europe, the UK working at Environmental Act, EPR, DRS, the pain, I imagine, of many people on this call.
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And then kind of things around kind of mandatory climate financial disclosures.
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So we've had the consultation in the UK. In the US and Canada, we're already seeing that.
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Even in the US, state level climate disclosure requirements. California is normally the state that leads there.
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I've got things like the FTC green guys from the U.S.
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and also as well I've mentioned here food loss and waste reduction.
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I spoke about EU and how they've put their targets in place but also the U.S. and Canada are showing that direction as well.
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So when we're looking at that kind of globally compliant product we need to consider all of the climate impacts or the environmental impacts that the product life cycle has on there.
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And life cycle is a key bit that we'll kind of touch on well. So, green claims and the legislative environment.
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I feel like this should be well-versed now across the industry, but just to be very clear, green claims often refer to different subjects, metrics, but the general definition is that they focus on those environmental metrics associated with a product or service.
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So working with food, we sometimes forget that green claims can be related to that delivered sales, like I said.
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So when people kind of self-service into your business, IT, for example.
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Green claims are no different to any other claims that you make on pack.
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They can be explicit or implied.
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They can be a statement, but they can also be symbols, logos, and graphics.
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that leads to consumers believing that there is some sort of environmental benefit of that specific product, maybe as well when you're making comparative claims.
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As we know, no claim should be misleading to a consumer.
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There's consumer protection in place, and that's what we're going to be talking about today.
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But the respect of green claims, we often affect it as greenwashing, deceptive nature.
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So the first bit, which won't be new, but will become relevant, I promise, as we move through, is CMA Green Claims Code.
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So the Green Claims Code is guidance. Be very clear that it is not legislation.
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And that was published back in 2021.
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It set out six principles to ensure those compliant communications. Unsurprisingly, number one was truthful and accurate.
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So claims must not exaggerate that environmental benefit that they provide or use it.
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General vague terms like a year of sustainability, we all know that. It must be kind of clear and ambiguous.
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So using plain language, I think sometimes when we're looking around green claims, looking around when you're in it day-to-day, you sometimes forget that there are vague terms, but there also are technical jargon that the general consumer may not understand. So just be clear with how you're communicating.
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The other bit, and this falls nicely into another point, is mustn't admit or hide important information.
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So don't just focus on the positive environmental aspects while hiding specific negative impacts.
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Probably you would have seen this in kind of oil companies are a good example of this, where adding wind turbines generating clean electricity in an advertisement while not communicating the rest of their business operations.
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And this brings me into as well that claims should not cherry pick particular stages.
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So, you've got to consider the full life cycle of your product or service, whether it's from sourcing new raw materials and production to transport and how they are disposed.
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And that brings us back to that consumer action, the unpredictable part of our supply chain.
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And then the other bits, you must be substantiated, so robust, credible, and up-to-date evidence.
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like I said, food supply chains are dynamic, they change.
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Are you confident that your data is up to date?
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Are you confident you can take your data and apply it to different scenarios or do you have to have different scenarios ready for when the CMA come knocking at your door asking, please can we see your substantiation for that claim?
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So the reason this is all applicable is because of the Digital Markets Competition and Consumer Act.
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After referred to as DMCCA, this is a key piece of legislation for incomes.
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So, a Receiver Order was sent in May 2024, and the enforcement powers were given to CMA around the summer time of 2025.
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And these new powers were put in place to set up a digital markets unit to enforce things side pricing, fake reviews, subscription contracts.
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However, those new powers weren't restricted to those three categories in that digital market unit.
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It seems that those new powers have given the CMA the ability to enforce the principles of the Green Claims Code because they are protecting the consumer from misleading communications.
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The funding as well that's to this business unit or this department unit is it demonstrates that governments are putting some effort behind consumer protection and holding businesses accountable for their claims they make around their business operations.
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As you can see from that last point on the slide, enforcement these claims cannot be significant.
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So direct infringement can result in up to 10% of global turnover as a fine, and that the minimum fine is £300 ,000 in this respect.
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And we'll come onto it later in the presentation.
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We've been speaking about products up until now, but actually the CMA's remit is far wider.
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It can include companies annual reports, your ESG reports, including any voluntary commitments you've made regarding the environmental impact of your operations.
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Given as well that many of the businesses will operate within the European Union, we've seen that the Green Claims Directive came into, was adopted by the European Council in 2024.
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And this proposed directive provided clear requirements around substantiating environmental claims, potentially enforcing requirements of life cycle assessment of products in order to make those environmental claims.
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Probably start to see a trend here in terms of life cycle of products.
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And when making those explicit claims around your product, you need to think about the business activities related to that product.
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So when making general environmental claims, you considered things like emission offsets, those types of things, or the indirect emissions associated, often referred to probably as scope free, the ones that are more likely to be out of your control.
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And also when you're kind of making comparative claims, this directive said that you needed to have both products or multiple product data available to be able to substantiate that links to consumers, so consumers can access all of the data.
20:03
So they're just examples, you might have realised some of the words I was using there were not that it's going to come into force and that is because it has been withdrawn.
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So all of those extensive fines, exclusions for public procurement processes associated with this Green Claims Directive, very similar to our penalties but this has been withdrawn.
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But not to worry I know you've all gone to so much effort to pull together all of the data you haven't left you high and dry.
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So all is not lost because we've now got the empowering consumers for the green transition and this directive is looking to empower consumers to make those sustainable purchasing decisions.
20:54
It's quite similar in the principles that laid out to the EU Green Claims Directive, and it entered into force in March 2024, and it must be transferred into national law by September 2026.
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So this major piece of legislation also meant two existing EU consumer laws, so the Unfair Commercial Practices Directive and also the Consumer Rights Directive.
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Again, we're looking at consumer rights, consumer protection, and the effort made there by governments.
21:31
The aim of this legislation was to, or is to, establish a legal baseline for addressing greenwashing within consumer communications, while introducing that mandatory requirement on product durability.
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So it bans the use, just like the other legislation, both in the UK and the EU, it bans the use of generic claims, carbon offsetting claims, and uncertified sustainability labels, which in the EU's view should force companies to remove vague marketing claims from their products and or services. Interestingly, as well, it looks to ban the claims of future performance.
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So, things like net zero by 2030, climate positive by 2040, all of those types of things.
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The banning of those spans far beyond the product's label.
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It is all around the business operations.
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This is where your company reports, ESG reports, those types of things all come into play.
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The unique feature when it's legally required of a product will be banned.
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So when we're talking about EUDR, palm oil, for example, if all palm oil has to be deforestation free, you can no longer claim palm oil being deforestation free within your products.
23:06
it almost is very similar to what we see around product ingredients and gluten-free claims and other claims and of similar nature.
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But it also means you need to look at kind of the logos on pack, meaning that kind of businesses will need to review the communications across all their products.
23:28
And I also kind of just wanted to touch on the EU eco-label.
23:31
It often sits in the background, no one really talks about it, but actually it was launched 30 years ago and they claim that it is the only EU-wide ISO 14024-1 environmental labeling scheme.
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This is important because we said there that you can't have uncertified sustainability labeling.
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This is one of the few that are ISO accredited, bound by regulation, and it was originally used to avoid the proliferation vehicle labeling schemes.
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So any labeling scheme available to the market before this regulation or the Green Claims Directive at the time came into force would be able to carry on, providing they meet the new criteria.
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However, with the EMPO regulation, we may start to wonder whether we'll start to see more use of this logo on products as the new regulatory powers come into force. So that's the legislative environment.
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There is, at the end of the day, a commercial business environment.
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So what do sustainable products bring to the market versus the conventional product?
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But I think when we're talking about commercial value of green claims, it's not surprising that consumer data shows that products can convince consumers to pay more for a product.
25:12
And data suggests that, I'm not sure about this for food, but although consumers want food to be affordable, some consumers will pay upwards of 25% more for a product when it's being marketed sustainable.
25:29
Now when we think about kind of the legislative environment.
25:33
When you're looking at products being sustainable, if we're looking at the co-regulation, if it's a legally requirement or legally required claim, so palm oil for example, in deforestation free, in theory you will no longer be able to make those in the EU market.
25:52
So these premium price tag sustainability claims are in the future potentially going to be linked voluntary commitments being marketed by a business which aren't built into the legislation.
26:07
So when that's not built into the legislation we have to think back in and specificities around kind of particular ingredients those type of things and this is where general consumer law will prevail.
26:19
Businesses without a viable plan for achieving the claims they are making and face enforcement action.
26:28
It ultimately comes down to misleading, which sometimes is referred to as kind of profiteering from making false claims and things like that.
26:36
And this is where the UK DMCCA comes into play.
26:42
We spoke about it earlier, but CMA wide range union in terms of their fines, fines are extensive, quite impactful from in a commercial sense, and businesses are facing legal action across the globe as a result of those business commitments to achieve sustainable targets.
27:03
How this kind of plays out is a bit of a waiting game, but it's things like when companies are using the UN Sustainability Development Goals in their reports, are their initiatives aligning to those UNSTGs and do you have a viable plan for achieving those time targets?
27:30
And the legal implications often lag, sorry, regulation is often lagging consumer expectation, so there's also legal action associated with some of the claims.
27:43
So businesses need to consider all of those commercial implications when they carry out their due diligence. It's a tightrope walk, basically.
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When you're navigating that complex area of communicating efforts in relation to sustainable business practice, you've got to make sure you've covered all your bases.
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In 2024, there was more than two and a half balance of active climate mitigation lawsuits.
28:07
I think in 2025 that has cut into in excess of 3 ,000.
28:13
So the other thing to consider here is legislative developments are requiring businesses to make publicly available more data around their sustainable business practices.
28:28
Things like CSR, all of your corporate social responsibility requirements, CSDD, CSRD, EUDR all require publicly published data from businesses, which only opens you up to more criticism of the business operations and negative environmental impacts.
28:52
So you can't just sit in the background publishing this data and maintain consumer trust, particularly if the operations are seen to be impacting the environment.
29:11
It kind of only fuels the fire, so to speak, when it comes to that erosion of consumer trust in your brand.
29:20
So communication being compliant is going to be tricky to navigate.
29:24
A good example of this, appreciate it's the US, but JVS USA have recently had entered into a settlement and this was around their net zero claims by 2040, greenhouse gas emissions.
29:45
It wasn't the actual claim itself, Back to our point about profiteering off false claims, they didn't have a viable plan for achieving a net zero greenhouse gas emission, and within their company reports there were two lines referring to the improved profitability or the premium price tag associated with sustainable products on the claims.
30:15
So, it just kind of puts it into perspective.
30:19
It might not necessarily be your product, it might be your business communications.
30:23
And it's not only legal, it's also consumer reports, NGOs. This is a great example, like the Wich Consumer Report.
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This was published in July 2025, and they reviewed 8 ,800 products on the market for green claims.
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The use of green claims about that verifiable or robust data formed the basis of this report.
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They used the six principles that we mentioned earlier for the green claims code as guidance for their methodology.
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So they built that framework, review models, and then they decided to publish the report and hold companies accountable when it comes to claims of their product.
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So you'll see here that, on average, three products contain three green claims.
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49% of those products didn't justify or they used vague terms.
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so we're failing on the principles there of CMA Green Claims Code, and 62% of them failed checks related to that.
31:43
So you could argue that the methodology and the potential bias on the review are flawed, but in the current environment with social media, you can't get away from these types of messages because it's easy for them to simplify those messages And they made all of this information made easily accessible for the majority of the population, so your consumers, so making it easy.
32:10
They made it easy for consumers to suggest and then make a quick decision by what they've seen on social media without delving into the details.
32:21
So it's really kind of important when we're thinking about the commercial environment to think about all of the factors including NGOs when we are embarking on a journey of publicly publicizing this data because it's a regulatory requirement.
32:43
So just wanted to kind of bring it into perspective as well what's kind of in market, what has been in market.
32:50
So using logos, like the ones on this slide, will require businesses to do substantial life cycle analysis and prove that to the regulatory bodies and justify figures used for life cycle assessment.
33:08
As we spoke about earlier, cherry picking particular parts of your product's environmental impact is no longer allowed.
33:21
So you need to think carefully before putting any of these types of loader on your product.
33:34
And then the generality of these claims has been highlighted by the European Commission.
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So we'll have to wait and see what happens to all of these labeling schemes and logos in relation to the MCO regulation or just wider sustainability regulation, but you really shouldn't be like kind of focusing on one hand of your product.
33:55
Maybe a little bit controversial, but we also kind of need to consider the recycling logos and the recycling claims we make on pack.
34:04
They're generally considered as straightforward informing the consumer of whether the packaging is recyclable, but they could also easily be seen as an implied green claim.
34:17
Developments within the recycling industry and like material innovation mean that sometimes recycling and the recycling streams aren't as straightforward as they seem on paper.
34:28
So we have to provide consumers with education instructions on how to correctly dispose of that packaging to reap the benefits of that sustainable packaging and the effort that gone into developing that packaging.
34:46
But we can't assume that consumers know what all of these various logos mean and they may interpret them as all being recycled in the same way.
34:56
And so the other consideration when you're placing these on your product is the availability of recycling facilities in the local area.
35:05
In the UK, not all councils, although there is regulation that is requiring them to do so in the coming years.
35:15
Not all councils have the ability to offer food waste or have the facilities available in the local area to recycle in the way in which producers intended.
35:28
So we need to consider the whole, again, the whole life cycle of the product including the consumer action at the end when we're making decisions around what placing on pack. So in summary, sustainable food systems form the foundation for your green claims.
35:48
The stakeholders across your supply chain are key for being able to substantiate and get the data you need to support those green claims.
35:57
Green claims should, that consideration for them should be built into product development pipelines.
36:05
Maybe I'm a bit biased in terms of being in regulatory affairs, but including regs early in your process is key to ensuring that you stay compliant when you're making those green claims and what elements of your product development you need to consider.
36:25
Like we said, DMCCA is probably your go-to in terms of when you're making green claims and ensuring compliance. You've then got the MCO directive.
36:34
There are lots of supporting regulations around both of these, but that's probably a good starting point when we're looking at green claims.
36:43
Like I said, collaboration across your supply chain, but also sometimes collaboration with your peers, your competitors in your category is key for achieving compliant claims.
36:55
And yes, consumers will pay a premium price.
36:58
The businesses need to ensure they've done their due diligence to ensure their claims are compliant and substantiated before going to market.
37:08
And so I like to leave kind of a finish on this slide is sometimes within the food industry, there's lots of small and medium enterprises, sometimes I leave all of this regulation and give it to people and actually it becomes overwhelming, no one knows where to start.
37:28
So the hardest part, I would say, of data gathering is just getting started, knowing where to start. So, I've left some questions here on the slide for people to consider.
37:41
But really, if you look at the process flow below in terms of getting started, it's just internally, what do you know about your business processes?
37:49
Who holds the data within your business that you need to make sure your green claims are compliant?
37:57
You embed governance across, we requirements around those now.
38:08
So ensure that all of the governance around the data that you hold is solid and you keep everything up to date.
38:16
Again we said collaborating across your supply base is imperative but then also embedding digital technology, ensuring that you have those digital technology tools to support you in that data gathering and ensuring that is pulled together in the manner and everyone's working from the same metrics, particularly when we're looking at databases for environmental data and environmental impact data. And like I said, category collaboration.
38:49
Sustainability is not a single person is going to solve this.
38:54
You need to collaborate across category to see and learn from each other.
39:02
So with that, just to say thank you very much for listening. If you've got any questions, like you said, please put them in the Q &A.
39:09
Here's my email address, take a visit to our website and also QR code for LinkedIn profile.
39:20
Cool, thank you very much Ed.
39:22
As we said earlier as well, we have been recording today, so we'll make sure to send that across to everybody afterwards as well, along with a copy of the slides.
39:30
Please do put any questions that you have in now.
39:32
We've had one come through already.
39:35
The question that we've had is, does this mean that companies which have things like trees and their logos will need to review them?
39:46
My advice would be yes.
39:49
It depends, obviously, with regulation and regulatory interpretation.
39:53
It all depends on how the consumer is going to interpret that.
39:56
So if you do have a tree in a logo and it puts something like sustainable eco-friendly big nose, but if it talks about carbon offsetting or if you're talking about planting trees for the next kind of generation and stuff absolutely needs to be reviewed and make sure you can plant and you've got that substantiation to support that if the authorities come asking.
40:24
Oh, thank you.
40:26
We've had another question just come through.
40:29
It says, you said we need a full LCA for a product.
40:33
How can we do this, for example, boiling the kettle to make tea when we have no control over how much water consumers boil or where they source their energy?
40:44
It's a really good question.
40:47
Like I said, consumer action or consumer activities are one of the most unpredictable bits of your supply chain.
40:58
I would say my suggestion would be that if you are going to make claims around your product flat cycle and you need to use average data or from databases or make a assumption based on verifiable information or data that you've got and then make that very clear in any claims you're making.
41:31
Yeah, tea, coffee, anything that involves cooking, all of those types of things.
41:36
As we know, there's variable energy usage across all of those appliances, so it's sometimes you just have to take your best guess and make sure you've got the evidence to show how you got there.
41:47
It's kind of like when you get, when you were told at to show your workings, that's what we need to do.
41:55
Okay, thank you. I think we've got time for two more questions quickly.
42:01
The first one is, are there any plans to sustainability label restrictions in the UK or is it just EU for now?
42:10
So, I would say, although it's not explicitly said within the DMCCA or any other legislation for the UK, you still need to consider the communication or the implied nature of that go or that eco score, whenever you're going to be using carbon footprint and those types of things, because it all comes back to consumer protection and the laws around that.
42:39
So yes, there are specific restrictions in the EU, but it doesn't mean that just because there specific restrictions in the UK that it's kind of a free-for-all.
42:49
You still need to do your kind of homework and be clear on what you're communicating to the consumer.
42:58
Thank you and the final question that we'll go for is you mentioned palm oil claims, RE deforestation, are RSPO logos still compliant to include on-pack?
43:12
It's funny when I was putting this presentation together that's the first thing that came to my the RSPO roundtable and the logos there.
43:21
I think providing that you're not making deforestation free specific claims around palm oil and things like that, being a member of RSPO roundtable just shows that you as a business are taking your climate responsibility seriously.
43:43
So there isn't actually any, I would say, negative impact on that.
43:51
Absolutely worth getting enforcement opinion on that, though, because you're right, that is one of the unknowns when we're kind of navigating these new regulatory challenges.
44:05
Cool, thanks very much, Ed.
44:07
We have had a few other questions, but I think we've run out of time now. So if anybody has got any others or would like Ed to answer then feel free to get in touch.
44:16
Ed's email is on the screen and in the follow-up email that we send you we'll include Ed's contact details in there as well.
44:23
So thanks very much everyone, thank you Ed for presenting and thanks everyone for joining.
44:28
I hope you all have a great rest of the week and see you another webinar again soon. Bye.