This article was written by Genee Consulting Ltd, a consultancy partner we work with, and is shared as part of our commitment to providing helpful industry insight.
"From Green Claims to Green Evidence: Could You Prove What Your Business Says About Sustainability?"
Recyclable, lower carbon, made with recycled materials, environmentally friendly. Businesses use environmental claims like these every day, whether on packaging, websites and social media, or in tenders and conversations with customers.
But there is an increasingly important question businesses need to consider: if somebody asked you to prove one of those claims, could you?
That might sound like something only large businesses or sustainability teams need to worry about. In reality, changes taking place both in Europe and the UK mean it is becoming relevant to businesses of all sizes – including those that may not think of themselves as making environmental claims at all.
What's Changing in Europe?
New EU rules designed to tackle misleading environmental claims came into effect on the 27th September 2026. They strengthen the rules around how businesses communicate environmental information to consumers, including the use of broad terms such as “green” or “environmentally friendly”, sustainability labels and some claims linked to carbon offsetting.
For UK businesses selling products or services to consumers in EU markets, these changes are important. Environmental information appearing on packaging, websites, advertising and other consumer communications may need to be reviewed to make sure that claims meet the requirements of the markets in which they are being made.
However, this isn't something UK-only businesses should simply dismiss as an EU issue.
What if your Business Only Operates in the UK?
The basic principle behind these changes is already very relevant here.
The UK's Competition and Markets Authority (CMA), which is responsible for protecting consumers from unfair business practices, has established a Green Claims Code. Put simply, businesses shouldn't make environmental claims that are misleading and should have good evidence to support what they say.
UK advertising rules take a similar approach. If a business makes a factual environmental claim, it should have appropriate evidence to back it up. Broad statements such as saying that a product is “green” or “environmentally friendly” can be particularly difficult to justify because they potentially suggest a very wide environmental benefit.
The consequences of getting this wrong have also become more significant. Since April 2025, the CMA has had stronger powers to enforce consumer protection law, including the ability to impose substantial financial penalties in serious cases.
Your Customers May Need Your Evidence Too
There is another reason this matters, particularly for businesses operating within supply chains.
Imagine that your business manufactures a product, supplies packaging or provides a service to another organisation. Your customer might ask how much recycled material is contained within a product, whether packaging is recyclable, what happens to your waste or what you're doing to reduce your environmental impact.
They may not simply be asking because sustainability is part of their procurement process. They could also need that information to support environmental claims they make to their own customers.
This has become an increasing area of focus in the UK. In January 2026, the CMA published guidance specifically looking at environmental claims across supply chains, including the responsibilities of retailers, brands, manufacturers and suppliers.
That means a business doesn't necessarily need to be making a big consumer-facing claim about being “green” for this issue to matter. The environmental information you provide to your customers may form part of the evidence they rely upon further along the supply chain.
For many SMEs, this may be where the change becomes most noticeable. Rather than a regulator suddenly asking questions, it could be an existing or prospective customer asking for better environmental information, more reliable data or evidence to support what you've told them.
What Does Good Evidence Look Like?
The answer will depend on the claim being made.
If you say that your packaging contains 50% recycled material, for example, you should be able to show where that figure came from. If you say you've reduced waste, you should know what period you're comparing it with and have figures that demonstrate the reduction.
Similarly, if your website says you're reducing your carbon emissions, there should be a credible calculation and a baseline behind that statement, and if you tell customers that improving environmental performance is a business priority, you should ideally be able to demonstrate the objectives, actions and progress that sit behind that commitment.
None of this means every SME needs to employ a sustainability manager or produce a lengthy environmental report. It does mean businesses benefit from having a more organised way of understanding what they're doing, measuring progress and keeping appropriate evidence.
Start By Getting Your Environmental House in Order
A useful starting point is simply to look at the environmental statements your business already makes.
What do you say on your website? What appears on your packaging or marketing materials? What environmental information do you provide in tenders? What do your sales teams tell customers? And what information are customers increasingly asking you to provide?
Then consider what sits behind those statements. Do you have reliable energy or waste data? Do you know your carbon footprint? Do you have an environmental policy? Have you identified the areas where your business has its biggest environmental impact? Are you setting objectives and recording the improvements you're making?
For businesses that already have much of this information, the exercise may simply highlight a few gaps. For others, it may show that environmental activity is taking place but isn't yet being measured or recorded consistently.
Where Investors in the Environment Can Help
Investors in the Environment (iiE) is an environmental accreditation programme designed to help organisations put that structure in place.
Rather than starting with what a business wants to say about sustainability, iiE helps organisations look at what they're actually doing. That includes understanding environmental impacts, measuring areas such as energy, waste and carbon, setting realistic objectives, putting actions in place and tracking progress over time.
It also looks more widely at how environmental responsibility is managed within the organisation, including areas such as procurement, communication, environmental projects, biodiversity and social value where these are relevant.
Progress is independently assessed as part of the accreditation process. This provides businesses with external recognition for the work they're doing, but just as importantly, it helps create a more organised body of evidence behind that work.
For an SME, there is a practical business benefit to this. Instead of trying to pull information together from scratch whenever a customer sends a sustainability questionnaire, asks a question during a tender or requests evidence of environmental performance, much of that information is already being measured, recorded and reviewed.
Of course, achieving iiE accreditation doesn't mean a business can automatically make any environmental claim it wants. A specific claim still needs appropriate evidence to support it. What iiE can do is help make sure there is genuine activity, measurement and continual improvement sitting behind the organisation's wider sustainability story.
Don't Stop Talking About the Good Things You're Doing
Greater scrutiny of green claims shouldn't mean businesses become afraid to talk about environmental progress.
If you've reduced waste, changed your packaging, cut energy use, introduced recycled materials or made another meaningful improvement, there is every reason to communicate it. Being specific about what you've achieved, explaining how you've measured it and avoiding claims that go further than the evidence are sensible principles to follow.
And for businesses that aren't quite there yet, this doesn't need to become another overwhelming compliance exercise. Start with what you already have, identify the gaps and gradually put better systems in place.
The EU's new rules have brought green claims back into the spotlight, particularly for UK businesses selling into European markets. But the wider message is relevant much closer to home. UK regulators already expect businesses to be able to support environmental claims with evidence, while customers and supply chains are increasingly asking for better environmental information too.
Ultimately, it comes down to the straightforward principle, if you say it, can you show it?
Taking the time to make sure the answer is “yes” could help your business communicate its environmental progress with greater confidence, respond more easily to customer requests and be better prepared as expectations continue to develop.
If you'd like to hear how other organisations are putting this into practice, join us at the iiE Sustainability Learning, Leadership & Celebration Conference in Newcastle on 25th November, where organisations ranging from major national businesses such as Greggs to small charities will share how they're approaching environmental management, building credible evidence and turning sustainability commitments into practical action. Book your free place at www.welcome.iie.uk.com/iie-2026.
More Information
At Genee, we work with Wastepack members to help them develop practical environmental management systems through Investors in the Environment. By taking a structured approach, businesses can improve efficiency, reduce costs and demonstrate the environmental credentials that customers are increasingly looking for.
Genee Consulting Ltd is the Northern Delivery Partner for Investors in the Environment. To find out more about the accreditation and how Genee can support your sustainability journey, contact us at jo@genee.org.uk.
