Why this area is scrutinised harder than others
Environmental claims influence purchasing decisions, they are difficult for a shopper to verify, and they have been widely overused. That combination is why the Competition and Markets Authority produced the Green Claims Code and why the area has attracted sustained attention across consumer goods.
Beauty is particularly exposed because the category is packaging-heavy, because natural positioning invites environmental language, and because independent brands often adopt claims from suppliers without checking whether they hold for the finished product.
A green claim is assessed on the impression it creates in the mind of an ordinary shopper, not on the technical accuracy of the words in isolation.
The principles, in practical terms
The Green Claims Code sets out principles that translate into a small number of practical rules.
- Be truthful and accurate. The claim must be correct for the thing it describes.
- Be clear and unambiguous. If a claim applies to the cap and not the bottle, that has to be apparent.
- Do not omit important information. A claim can mislead by leaving something out, for example that recycling is only possible where a particular facility exists.
- Make fair comparisons. Comparisons must be like for like and explained.
- Consider the full life of the product. A benefit at one stage can be offset elsewhere, and a claim implying overall benefit needs to account for that.
- Be substantiated. Evidence needs to exist before the claim is published.
| Claim | What it has to account for |
|---|---|
| Recyclable | Whether it is recyclable in practice, and whether separation is needed |
| Refillable | Whether refills are actually available and obtainable |
| Plastic free | Every component, including seals, liners, pumps and coatings |
| Biodegradable | The conditions required, and whether they are realistic for a consumer |
| Compostable | Whether it means home or industrial composting |
| Carbon neutral | What was reduced, what was offset, and on what basis |
Source: Framework is this paper's own; the expectations derive from the CMA Green Claims Code.
Orientation only, not legal advice. Environmental claims are assessed on the overall impression created for consumers.
The specific traps in beauty packaging
Recyclable
The most common claim and one of the easiest to get wrong. A pack made of a recyclable material is not necessarily recyclable in practice, and mixed material components frequently are not. If the claim depends on the consumer separating parts, say so. If it depends on facilities that are not widely available, that is important information.
Refillable
Only meaningful if refills are actually available, in a form the customer can obtain, at the time they need them. A refillable claim on a product with no refill in stock is a problem.
Plastic free
Frequently inaccurate, because seals, liners, pumps and coatings often contain plastic. Check every component, including the ones you did not specify.
Biodegradable and compostable
These are technical terms with defined conditions. Compostable often means industrially compostable, which is a materially different proposition for a household consumer, and that difference is exactly the kind of important information that should not be omitted.
Carbon language
Claims about carbon neutrality or offsetting have attracted particular scrutiny. If you make one, understand what has actually been done, what has been offset rather than reduced, and be prepared to explain both.
Why general terms are worse than specific ones
Terms such as eco-friendly, sustainable, green and kind to the planet are attractive precisely because they are broad, and that breadth is the problem. A broad term implies a whole-product benefit, which then has to be supported across the whole product.
A specific claim is easier to evidence, harder to challenge and more persuasive to a shopper who has learned to discount vague language. Saying exactly what you changed, and what it achieved, is a stronger commercial position as well as a safer one.
| General claim | Specific version | Why the specific version is better |
|---|---|---|
| Eco-friendly | Bottle is a single material and widely recycled | Evidenced, checkable, and more informative |
| Sustainable packaging | Carton uses recycled fibre, stated proportion | Applies to a named component with a figure |
| Kind to the planet | No plastic in the outer pack or the seal | Verifiable, and says something a shopper can use |
| Plastic free | Plastic free outer packaging, pump contains plastic | Complete rather than partial |
Source: Working model used by this paper, not a measurement.
Specific claims are usually easier to substantiate and more persuasive, because consumers have learned to discount vague environmental language.
Ingredient and sourcing claims
Environmental claims about ingredients carry their own requirements. Claims about sourcing standards should reflect what is actually verified, and where you rely on a certification, you should understand what it covers and whether your specific supply is within its scope.
Be careful with claims that imply a benefit for a whole formulation on the basis of one ingredient. A product containing a small proportion of a responsibly sourced ingredient is not thereby a responsibly sourced product.
The connection between environmental language and natural positioning is covered in what clean and natural actually mean in UK cosmetics.
Claims for a service business
Salons and studios make environmental claims too: about water use, energy, waste, product disposal and packaging take-back. The same principles apply.
Two practical points. Take-back schemes need to actually result in what you say happens to the material, and you should know what that is rather than assuming. And claims about a whole business, such as being sustainable, are broad claims that would have to be supported across the whole operation, which is a much heavier evidential burden than a specific claim about one thing you changed.
What evidence to hold
Before publishing a claim, hold: the specification confirming the material composition of each component; documentation supporting recyclability or compostability, including the conditions required; supplier confirmations for ingredient sourcing claims; the calculation and method behind any figure; and a dated record of the claim wording that was approved.
Then review it when anything changes. A component substitution by a supplier can invalidate a packaging claim without anyone noticing, which is why the packaging documentation habits described in packaging compliance and cost matter here too.
A defensible position for a small brand
Make fewer claims and make them specific. Say what you changed, what it applies to, and what it does not. Avoid general adjectives that imply whole-product benefits. Publish the detail somewhere accessible so that an interested customer can check. And treat any claim as something you will have to defend, because the standard applied is what an ordinary shopper would take from it, not what you meant.