Going Green? Advice for Marketing Your Eco Products

Do your marketing efforts fall foul of new draft guidance issued by the Competition and Markets Authority (CMA)? Ahead of the complete guidance in September 2021, we consider the six key principles being proposed and how they might encourage footwear businesses to re-examine their ‘green’ claims.

As consumer demand for sustainable, ethical and recyclable products continues to grow, businesses in the footwear sector are increasingly developing new lines and innovative materials that aid in making their products ‘green’.

“In 2019, UK consumers spent £41 billion a year on ethical goods and services – almost 4 times as much as people spent two decades ago.”

This determination to preserve and protect the planet should be applauded and promoted to the end consumer, allowing them to make an informed decision where to spend their money. The challenge facing the Competition and Markets Authority (CMA) is the swathe of misleading comments being introduced to the market that are unsubstantiated, potentially confusing and ultimately risking consumer confidence.

What does misleading behaviour look like?

  • exaggerating the positive environmental impact of a product or service
  • using complex or jargon-heavy language
  • implying that items are eco-friendly through packaging and logos when this is not true

“Some 40% of green claims online could be misleading.”

To tackle this, the CMA has issued some draft guidance, which it is welcoming feedback on until 16 July 2021. The guidance consists of six principles that businesses should follow when communicating their green credentials and communicating with customers.


  • must be truthful and accurate: Businesses must live up to the claims they make about their products, services, brands and activities
  • must be clear and unambiguous: The meaning that a consumer is likely to take from a product’s messaging and the credentials of that product should match
  • must not omit or hide important information: Claims must not prevent someone from making an informed choice because of the information they leave out
  • must only make fair and meaningful comparisons: Any products compared should meet the same needs or be intended for the same purpose
  • must consider the full life cycle of the product: When making claims, businesses must consider the total impact of a product or service. Claims can be misleading where they don’t reflect the overall impact or where they focus on one aspect of it but not another
  • must be substantiated: Businesses should be able to back up their claims with robust, credible and up to date evidence

“This direction comes at a time when more than half of UK consumers take environmental considerations into account when buying products,”

Andrea Coscelli, Chief Executive of the CMA

It is vitally important that BFA members consider these points when crafting marketing materials, ecommerce product descriptions, packaging and labelling.

“In 2020, the Competition and Markets Authority announced that it was investigating the impact of green marketing on consumers. According to its research, some 40% of green claims made online could be considered misleading. I don’t want to see the footwear sector fall into this trap, which is why we welcome this clear list of top tips to follow. This is only draft guidance right now, but BFA members have the opportunity to get ahead and clean-up their act ahead of the final guidance, which is due in September 2021.” 

Lucy Reece Raybould, Chief Executive Officer of the BFA

Here are some case studies outlined by the CMA to get you thinking about your own business’ green claims and whether they are accurately disclosed and substantiated:

  • A loaf of bread is labelled as “Organic Sourdough”. Sector-specific rules mean food products must be made from at least 95% organic ingredients to be labelled as organic. A claim would be misleading if that threshold is not met.
  • A company selling toiletries online presents a range of products with a green banner across the corner of the image stating, “save our seas – these are micro bead free”. This is likely to be misleading as it suggests a benefit in comparison to other products, when in fact micro beads are banned in the UK and should not be in any products.
  • A comparative claim that a footwear range is now “greener” is unlikely to be fair and meaningful on its own. It risks misleading consumers as the claim does not make clear the basis for the comparison.

“Many businesses are already doing the right thing by being clear and upfront about how green a product really is, but that’s not always the case. We’re concerned that people are paying extra for so-called ‘eco-friendly’ products and those businesses which are genuinely investing in going green aren’t getting the recognition they deserve.”

Andrea Coscelli, Chief Executive of the CMA

Further Reading

Related figures and statistics on this topic can be found in the CMA’s 
‘Making environmental claims: a literature review’.

More examples and case studies can be found in the CMA’s 
Draft Guidance on Environmental Claims.

Read more about how the CMA is supporting the transition to a low carbon economy in its 2021/22 Annual Plan.

BFA Resources:
Sustainability and the COVID-19 pandemic
Pre-loved footwear as a sustainable choice