The demand for environmentally responsible packaging is rapidly growing. Shoppers are paying more attention to the materials used in the products they buy, and brands have responded by making bold sustainability claims on their packaging and promotional materials. Among these, claims about biodegradable materials have become especially common, as businesses look for ways to demonstrate their commitment to reducing plastic waste and environmental harm. However, many of these claims have come under scrutiny from regulators, as there has been growing concern that some companies exaggerate or misrepresent the environmental benefits of their products.
In response, the Competition and Markets Authority (CMA) introduced the Green Claims Code to provide clear guidelines for businesses making environmental claims. The Code seeks to ensure that companies market their products in a way that is truthful, accurate, and backed by reliable evidence.
For companies using biodegradable labels, this development has created a pressing need to re-examine product descriptions, label wording, and supporting documentation. The Code has already had a significant impact on how brands communicate sustainability, and those using biodegradable packaging materials must now pay much closer attention to the details of their claims.
Understanding the Green Claims Code
The Green Claims Code was formally launched in September 2021 as part of the CMA’s efforts to address rising concerns about “greenwashing.” This term refers to the practice of making environmental claims that are exaggerated, misleading, or outright false, with the aim of influencing consumer purchasing decisions. Prior to the Code’s introduction, the CMA conducted research which revealed that up to 40% of green claims made by businesses could potentially mislead consumers. This prompted the regulator to take action by developing clear compliance guidelines.
The Code applies broadly across all sectors, covering any business operating in the UK that makes environmental claims. This includes claims on product labels, online advertising, social media promotions, and even verbal statements made by sales representatives. The scope of the Code ensures that greenwashing is tackled across every stage of the customer journey.
The Code sets out six key principles that businesses must follow when making green claims:
- Claims must always be truthful and accurate, without exaggeration or omission of facts.
- Claims must be presented clearly and unambiguously, so that consumers can easily understand them.
- Companies must not omit important information that could affect the understanding of a product’s environmental impact.
- Any comparisons made with other products must be fair, meaningful, and based on like-for-like metrics.
- Environmental claims must take the full life cycle of the product into account, from production through to disposal.
- Claims must be backed up with credible, up-to-date, and verifiable evidence.
These principles are highly relevant for biodegradable packaging and labels. A claim that a label is “biodegradable” is not acceptable without clear substantiation, especially if it fails to explain under what conditions the material breaks down, how long it takes, and what environmental impacts remain after decomposition. The Code aims to stop companies from using attractive-sounding claims as a marketing tactic without delivering on those promises.
Why Biodegradable Labels Face Scrutiny
Biodegradable materials are often promoted as a simple solution to the plastic pollution problem, but in practice, their environmental benefits can vary significantly. Many products labelled as biodegradable only break down under very specific conditions, such as in industrial composting facilities, which are not available to most households. In landfill environments, which represent the end destination for much of the UK’s waste, these materials can degrade extremely slowly or fail to break down at all. This gap between marketing claims and real-world outcomes is one of the main reasons biodegradable labels are receiving greater regulatory attention.
Part of the issue comes from the use of broad or ambiguous language. Claims like “biodegradable,” “eco-packaging,” or “green labels” can mislead customers into believing that the product will naturally and safely break down in any setting. This can lead to poor disposal practices, where consumers incorrectly assume the packaging will harmlessly decompose in household bins or even as litter. Misleading claims can therefore create more environmental harm rather than reduce it.
The CMA’s investigations have highlighted several problematic patterns in how businesses describe biodegradable products. Some companies have failed to specify the time frame for decomposition or have exaggerated the speed of breakdown. Others have promoted biodegradability without disclosing that specialist waste treatment processes are needed, leaving consumers with a false sense of environmental responsibility.
In recent years, high-profile enforcement cases have emerged. One UK retailer had to pull certain products from sale after claims about biodegradable packaging could not be supported by evidence. Home composting tests showed that the materials failed to decompose within the advertised time frame. These examples show why biodegradable labels have become a focus area for regulatory action, with the CMA keen to stamp out misleading claims across the board.
How to Make Compliant Biodegradable Claims
Complying with the Green Claims Code is not just a matter of changing marketing language—it requires businesses to undertake a thorough review of the evidence supporting their claims. For biodegradable labels, this involves careful testing, documentation, and transparent communication to consumers. The CMA advises companies to be prepared to demonstrate that their claims hold true under conditions that reflect real-life consumer use.
Firstly, businesses must obtain credible evidence from independent testing bodies that the label material biodegrades in specific environments. This means conducting laboratory or field tests under conditions such as home composting, industrial composting, soil burial, or aquatic environments, depending on the likely disposal route. Simply relying on the properties of raw materials is not enough; the finished product must be tested in its entirety.
Secondly, businesses must avoid blanket statements. A compliant claim will provide detail on:
- How long the material takes to break down under specific conditions, with actual time frames stated clearly.
- The exact environments where biodegradation occurs, such as home composting within 12 weeks or industrial composting within 90 days.
- The end result of the decomposition process, including confirmation that no harmful residues or microplastics remain.
Recognised certifications can help provide reassurance, but they do not automatically guarantee compliance with the Code. Certifications like EN 13432 (for industrial compostability) or OK Compost labels from TUV Austria must be accurately explained on the packaging, specifying their limitations and scope. Businesses should also audit the full life cycle of their labels, considering factors such as production emissions and transport impacts, since the Code requires life cycle thinking.
Finally, companies must keep their claims up to date. Any changes in product composition, waste disposal infrastructure, or scientific understanding should trigger a review of the claim. Documenting the review process and maintaining records of evidence is considered good practice to demonstrate compliance if challenged.
Best Practices for Labelling Biodegradable Packaging
Making legally compliant claims is only one part of responsible environmental marketing. Companies should also focus on creating labels that are genuinely useful and informative to consumers. Clear, honest labelling not only avoids regulatory penalties but also helps build trust and long-term brand value.
Some of the best practices for labelling biodegradable packaging include:
- Replacing absolute claims like “100% biodegradable” with more qualified statements, such as “biodegrades within 12 weeks in industrial composting conditions, certified to EN 13432.”
- Providing straightforward guidance on disposal, explaining whether the packaging is suitable for home composting or must be collected through specialised channels.
- Using easy-to-understand language free from jargon, so that all consumers, regardless of their environmental knowledge, can make informed choices.
- Including details on what happens during the decomposition process, such as highlighting that the label breaks down into water, carbon dioxide, and biomass without leaving microplastics behind.
- Distinguishing between related but different concepts, such as biodegradable, compostable, and recyclable, and clearly explaining which applies to the product.
Additional transparency measures, such as QR codes linking to in-depth product information, can also improve consumer understanding. Some brands choose to include visual icons summarising key information, which can be particularly useful for shoppers making quick purchasing decisions. Overall, combining technical accuracy with user-friendly communication is the recommended approach to compliant biodegradable labelling.
How Retailers and Supply Chains Are Responding
The introduction of the Green Claims Code has not only affected manufacturers but has also prompted changes in how retailers and supply chains approach biodegradable packaging. Many large retailers in the UK, including supermarkets and high-street brands, have introduced stricter internal policies on green claims, requiring suppliers to provide detailed evidence before products are accepted for sale.
Retailers are increasingly conducting audits of packaging claims, especially those related to biodegradability, to ensure they align with the Code. Some have introduced preferred supplier lists for certified compostable or biodegradable materials and have begun phasing out products with unsubstantiated or vague claims.
Supply chain partners, such as packaging converters and label manufacturers, are also adapting by offering clearer documentation and standardised testing reports. Many are investing in new product lines that meet recognised certifications, ensuring easier compliance for end brands.
This shift within supply chains means that businesses at all stages, from raw material producers to retailers, are being held accountable for the accuracy of environmental claims.
Penalties for Non-Compliance
The CMA has been clear that it is ready to take firm action against businesses that fail to comply with the Green Claims Code. Non-compliance can lead to a range of enforcement actions, starting with formal warnings and requests to change misleading advertising. For more serious breaches, the CMA can pursue legal proceedings, which may result in financial penalties, forced product withdrawals, and restrictions on future marketing activities.
One of the key risks of failing to comply is reputational damage. Cases of false environmental claims often attract public attention, especially when reported by consumer watchdogs or picked up by the media. Negative publicity can lead to a significant drop in consumer trust, reduced sales, and long-term harm to brand image. In today’s market, where many consumers are highly engaged with sustainability issues, the cost of reputational damage can be even greater than direct financial penalties.
Companies may also face challenges from competitors, industry bodies, or environmental groups if they are seen to be unfairly gaining market advantage through misleading claims. This can lead to regulatory complaints, industry disputes, or legal action under advertising standards regulations.
Since launching the Green Claims Code, the CMA has made it clear that packaging and labelling will remain a priority area for enforcement. Businesses that sell products with biodegradable labels are advised to act swiftly in reviewing their claims and making any necessary changes to avoid these consequences.
Conclusion
The introduction of the Green Claims Code has raised standards for environmental marketing in the UK. For companies using biodegradable labels, the message is clear: claims must be honest, clear, and fully backed by evidence. Vague promises of biodegradability are no longer acceptable, and those who fail to meet the requirements face increasing regulatory scrutiny and the risk of enforcement action.
Companies that take a responsible approach to biodegradable claims can position themselves as industry leaders in transparency and environmental responsibility. In doing so, they can contribute to reducing plastic pollution while offering honest and meaningful eco-friendly alternatives in the market.