4 green-claims checks for a Bristol content marketing agency

What to take away

Why green claims carry regulatory risk for Bristol agencies

Bristol's agency scene leans on environmental and engineering clients. That is a good fit for the city and a poor fit for loose language. A content agency writing about carbon, recyclability or renewable sourcing is producing a marketing claim, and marketing claims are regulated.

The Competition and Markets Authority enforces consumer protection and competition law, and its green claims work sits inside that remit. The Competition and Markets Authority - GOV.UK page sets out that remit.

The underlying prohibition on misleading commercial practices comes from the Consumer Protection from Unfair Trading Regulations 2008, which make a misleading action or omission a breach in itself.

The ASA handles the advertising side. Its advertising codes apply to ads and to marketing communications, which includes plenty of what agencies publish on a brand's behalf. A blog post that promotes a product can fall inside that scope. So can a paid social caption, a landing page or a video script. The CAP Code applies to non-broadcast marketing and the BCAP Code to broadcast advertising.

For South West sustainability content, the practical risk is not a single bad sentence. It is a pattern of vague claims across a website, a campaign and a set of product pages. Regulators read the whole picture.

Bristol teams also sit near a lot of technical subject matter: heat pumps, marine engineering, battery storage, food waste. Writers who are not close to the engineering tend to soften the numbers. That softening is where claims drift.

Check one: the CMA Green Claims Code tests

The CMA Green Claims Code is the starting point for any sustainability content claim. It asks whether a claim is truthful and accurate, clear and unambiguous, and complete. It also asks whether it is substantiated, whether comparisons are fair, and whether the claim covers the full lifecycle of the product or service.

The lifecycle test catches most Bristol examples. A packaging line can be recyclable in a lab and unrecyclable in a kerbside bin. A building material can be low carbon to make and high carbon to transport.

A useful habit is to run the six tests as a brief-level gate. If a client's claim fails any test, it does not go into the content plan. That is cheaper than unpicking a published campaign.

Agencies that check advertising rules before a brief tend to catch this at the planning stage, when the wording is still fluid.

Check two: ASA evidence and substantiation rules

The ASA's evidence rules work on the impression a claim creates. If a headline says a product is sustainable, the ASA will ask what evidence supports that impression. Fine print rarely rescues it. CAP Code rule 3.7 requires documentary evidence for objective claims before publication; BCAP Code rule 3.9 sets the corresponding requirement for broadcast ads. Section 11 of the CAP Code covers environmental claims.

Qualifiers matter. Words like "helps", "designed to" and "supports" reduce the strength of a claim, but they do not remove the need for evidence. A claim that something "helps reduce emissions" still needs something behind it.

Absolute terms are the riskiest. "Carbon neutral", "zero waste", "100% recyclable" and "eco-friendly" each imply a standard the client may not meet. "Eco-friendly" is especially weak because it has no agreed definition.

Comparative claims need a clear basis. "Greener than" needs a named alternative, a measured difference and a fair method. Without all three, the claim invites a complaint.

Bristol agencies also handle regulated sectors where a second rulebook applies. Financial promotions for green investment products sit under FCA rules, including COBS 4.2.1R in the FCA Handbook, which requires communications and financial promotions to be fair, clear and not misleading. Health and nutrition claims on foods are subject to specific rules; the Great Britain Nutrition and Health Claims Register identifies authorised claims. Content teams should ask early which regime applies.

Where a campaign collects data, consent and claims are the two areas that attract the most scrutiny. The guidance on consent and claims is worth reading before any lead-generation campaign goes live.

Check three: records that prove a claim

Substantiation records are the file an agency or client can hand over when a claim is questioned. If the file does not exist, the claim does not exist.

What belongs in it:

Records need an owner and a location. A folder on one account manager's laptop is not a record. It should sit somewhere the client can access after the agency relationship ends.

Digital records should be findable and readable years later, which is where record-keeping standards help. Keeping the evidence in the same system as the published asset saves time during a complaint. ISO 15489-1:2016, Information and documentation — Records management — Part 1: Concepts and principles, is a general standard that can inform how records are organised; it does not set a specific retention period for green-claim files.

For a Bristol firm selling a refillable cleaning product, the claim "bottle made from 100% recycled plastic" needs a supplier declaration naming the recycled content and the standard used. The claim "refill reduces plastic waste by 80%" needs a calculation, a stated baseline and the boundary of the comparison.

The claim "carbon neutral delivery" needs offsets, a verification route and a statement of what is and is not included. Three claims, three separate evidence files.

Check four: wording that avoids misleading impressions

Wording is where most complaints begin. The test is what an ordinary reader takes away, not what the writer intended.

Common fixes:

| "Eco-friendly" | The broad term does not identify the environmental benefit and may imply an unsupported overall claim. | "The bottle is made from 100% recycled plastic; the cap is not included." | | "Greener than alternatives" | It names no alternative, measured difference or fair method. | "This refill reduces plastic waste by 80% compared with [stated baseline], measured within [stated boundary]." | | "Carbon neutral delivery" | It leaves unclear which emissions are covered and what offsets and verification support the claim. | "We offset [specified delivery emissions]; see [the offset method and verification]." |

Specific wording is easier to defend and usually reads better. It also gives the writer something concrete to say.

Visuals carry claims too. A green leaf icon on a product page implies an environmental benefit. A stock photo of a wind farm beside a fossil-fuel client implies something the client cannot support. Alt text and captions count.

Agency teams should agree a house style for green terms. Ban the words nobody can define, list the terms that need sign-off, and keep the list short enough that people use it.

Broader rules and ethics questions, such as how a client's values sit against the work, also belong in this conversation rather than after it.

What to do when a client cannot evidence a claim

Do not publish it. That is the short answer, and it is usually the cheapest one.

The longer answer has three routes. First, rewrite the claim as an ambition with a date: "we aim to cut packaging weight by 20% by 2028". An ambition is not a performance claim, provided the wording is clearly forward-looking and the plan is real.

Second, narrow the claim to the part that is evidenced. If a supplier confirms recycled content in the bottle but not the cap, say so. Partial truth beats a whole claim that fails.

Third, drop the claim and find a different angle. Plenty of sustainability content works without a headline claim: process, people, supply chain, lessons learned.

Where a client refuses to change wording, put the advice in writing. Note the claim, the missing evidence and the date. That note protects the agency and gives the client a reason to reconsider.

Clients also need to know how their own disclosure policy covers claims, contributors and paid partnerships. A short written policy saves arguments later.

For wider sector guidance, the Sustainable Marketing Hub from the Chartered Institute of Marketing collects practical material on making and supporting sustainability claims.

Common questions