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 organisations of all sizes – including those that may not think of themselves as making environmental claims at all.

And from our work with organisations across different sectors, we're seeing another important change too. Customers, commissioners and larger organisations are increasingly asking their suppliers for better environmental information. Being able to evidence what you're doing is becoming useful not just for sustainability communications, but for doing business.

What's changing in Europe?

New EU rules designed to tackle misleading environmental claims came into effect on 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 or business 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.

So, while the EU changes provide a timely reason to look at this issue, the bigger story isn't simply about new European legislation. The direction of travel is towards businesses being expected to demonstrate the evidence behind what they say about their environmental performance.

Your customers may need your evidence too

There is another reason this matters, particularly for organisations operating within supply chains.

Imagine that your business manufactures a product, supplies materials or packaging, provides a service, or works as part of a larger contract. Your customer might ask about recycled content, waste, carbon emissions, environmental policies or what you're doing to reduce your environmental impact.

They may be asking because sustainability forms part of their procurement process. But increasingly, they may also need reliable information from their suppliers to understand and evidence their own environmental performance.

This has become a growing 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 your organisation doesn't necessarily need to make a big consumer-facing claim about being “green” for this to matter. The environmental information you provide to a customer could form part of the evidence they rely upon further along the supply chain.

For many SMEs and smaller organisations, this may be where the change becomes most noticeable. It may not be a regulator asking questions. It could be an existing customer introducing new sustainability requirements, a potential client asking for environmental information in a tender, or a larger organisation wanting better data from its supply chain.

What does good evidence look like?

If you say 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 carbon emissions, there should be a credible calculation and baseline behind that statement. 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.

And this isn't just about numbers. An environmental policy, clear responsibilities, action plans, evidence of completed projects, procurement processes and regular reviews can all help demonstrate that environmental commitments are being translated into action.

None of this means every organisation needs a sustainability manager or a lengthy environmental report. It does mean there is value in having an organised way of understanding what you'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 what your organisation already says about sustainability.

What does your website say? What appears in your marketing materials? What environmental information do you provide in tenders? What do your sales or business development teams tell customers? What do you say on social media? And what information are customers increasingly asking you to provide?

Then look behind those statements. Do you have reliable energy and waste data? Do you understand your carbon footprint? Do you have an up-to-date environmental policy? Have you identified your most important environmental impacts? Do you have objectives and actions in place? And are you recording the improvements you're making?

For some organisations, this exercise may simply identify a few gaps. For others, it may reveal something we see quite frequently: a lot of good environmental activity is already happening, but the organisation isn't consistently measuring, recording or communicating it.

That's where a structured approach to environmental management can make a real difference.

Where Investors in the Environment can help

At Genee, we support organisations across the North of England through Investors in the Environment (iiE), a practical environmental accreditation programme designed to help organisations understand, manage and improve their environmental performance.

Rather than starting with what an organisation wants to say about sustainability, iiE starts with what it's actually doing.

That means understanding environmental impacts, measuring areas such as energy, waste and carbon, putting policies and responsibilities in place, setting realistic objectives, taking action and tracking progress over time. It also considers areas including procurement, communications, environmental projects, biodiversity and social value where these are relevant to the organisation.

Progress is independently assessed as part of the accreditation process. That provides external recognition for the work being done, but there is another increasingly important benefit: it helps create an organised body of evidence behind your environmental activity.

For smaller organisations in particular, that can be valuable. Instead of starting from scratch whenever a customer sends a sustainability questionnaire, an environmental question appears in a tender or someone asks for evidence of progress, much of that information is already being measured, recorded and reviewed.

Of course, achieving iiE accreditation doesn't mean an organisation can automatically make any environmental claim it wants. A specific claim still needs appropriate evidence to support it. What iiE can do is help ensure 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 organisations become afraid to talk about environmental progress.

If you've reduced waste, changed your packaging, cut energy use, introduced recycled materials, worked differently with suppliers or made another meaningful improvement, there is every reason to communicate it.

The important thing is to be specific about what you've achieved, explain how you've measured it and make sure the claim doesn't go further than the evidence.

For organisations that aren't quite there yet, this doesn't need to become another overwhelming compliance exercise either. Start with what you already have, identify the gaps and gradually put better systems in place.

The new EU 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 environmental claims to be supported by evidence, while customers, commissioners and supply chains are increasingly asking organisations for better environmental information.

Ultimately, it comes down to one straightforward principle, if you say it, can you show it?

Taking the time to make sure the answer is yes can help you communicate your environmental progress with greater confidence, respond more easily to customer and tender requirements and be better prepared as expectations continue to develop.

See how other organisations are doing it

If you'd like to hear how organisations are putting this into practice, join us at the iiE Sustainability Learning, Leadership & Celebration Conference in Newcastle on 25th November.

We'll be bringing together organisations at very different stages and of very different sizes – from major national businesses such as Greggs to small charities – to share how they're approaching environmental management, responding to growing expectations and turning sustainability commitments into practical action.

The event is free to attend and open to iiE members and non-members.

Book your place at: welcome.iie.uk.com/iie-2026.

If you're interested in putting a more structured approach behind your own environmental activity, Genee delivers Investors in the Environment across the North of England, supporting organisations from those taking their first steps through to those with well-established environmental programmes.