Retailer Green Claims Forum Q2 2025: Unifying Marketing, Compliance and Sustainability Teams
In April, the BRC hosted the third session of the BRC and Provenance Retailer Green Claims Forum for 2024/25. Read on for a full summary.
About the Retailer Green Claims Forum
With increasing legislation on green claims across the UK and EU, the BRC and Provenance Retailer Green Claims Forum aims to facilitate structured collaboration between retailers and sustainability leaders to address the issues and opportunities in communicating about sustainability in a compliant way. The forum provides a platform to examine current approaches to brand- and product-level green claims, explore industry best practice when communicating about sustainability, and create an open-source data standard for compliant green claims.
Our previous forums have celebrated extensive participation from industry, having hosted 50+ leading retailers (with 100+ active members), alongside leading subject experts.
Session 3: Unifying Marketing, Compliance and Sustainability Teams
Access the full slides from the session here.
Regulatory update and Q&A
Mike Coates, Assistant Director at the Competition and Markets Authority (CMA) provided a refresher on the Green Claims Code, with an update on the CMA’s new powers under the DMCC Act 2024.
- New enforcement powers for consumer green claims: Core requirements for green claims remain unchanged, and apply to all businesses, regardless of size or turnover. However from 6th April, the CMA has adopted new powers to make decisions on whether a business has breached consumer protection law and impose resultant fines of up to 10% of global turnover. View approach document here. The CMA have not set out which sectors or businesses will be prioritised in investigations, but will target practice that makes consumers vulnerable (e.g. false information or hidden fees).
- Retailer accountability for third-party brand claims: Multi-brand retailers are responsible for green claims made by third-party brands they sell. Retailers are not required to hold substantiation evidence, but they should conduct appropriate due diligence to gain assurance that brand claims are validated. The CMA may approach the brand directly if sold by multiple retailers, but this remains context-dependent.
- Support for industry collaboration on green claims: Industry collaboration could bring clarity to and reduce friction between retailers and brands, given an approach is compliant with competition law requirements. View the CMA Green agreements guidance or contact the CMA directly at sustainabilitytaskforce@cma.gov.uk.
Peer discussion and shared learnings: Bridging the gap between marketing, compliance and sustainability teams
We heard from retailers on the common challenges and best practice in aligning sustainability, marketing, and compliance teams to ensure truthful, clear, and substantiated environmental claims. A number of live polls during the session provided insight into some of the topics covered.
Where do sustainability, marketing and compliance teams clash, and what solutions have you found effective in improving coordination?
- Significant difficulties emerge from the tension between managing the use of engaging, consumer-friendly brand language versus terminology that is legally compliant from a regulatory perspective.
- Retailers identified the following solutions to mitigate the tension between marketing and compliance.
- Cross-team education on compliance requirements and restrictions.
- Development of pre-launch checks to streamline the sign-off process, with proactive collaborative discussions between teams.
- Creation of a ‘bank of claims’ for marketing teams to utilise pre-approved sustainability language.
- Recognising the possibilities of sustainability in marketing – that collaborations can result in creative communications that are both compliant and compelling to consumers.
Do marketing KPIs support or undermine accuracy and compliance on green claims?
- Poll results revealed the majority of participants believed marketing KPIs moderately or strongly undermine accuracy and compliance on green claims.
- Sales and growth metrics are often prioritised, however marketers noted the opportunities for embedding sustainability metrics into all commercial campaigns.
How often are compliance and legal teams brought in to remedy a sustainability clam after it’s been published?
- 71% of respondents had seen compliance/legal teams being brought in to remedy a sustainability claim after it had been published online/on-pack, often as a result of legacy claims or an unclear process for verifying claims.
- Identified solutions included introduced a dedicated green claims section in product approval forms.
On green claims, is sustainability’s agenda more aligned with compliance’s or marketing’s objectives?
- 74% of respondents believed sustainability’s agenda is typically more aligned with compliance’s objectives over marketing.
Next steps for the Green Claims Forum
We are actively exploring the most appropriate formats of support for retailers on Green Claims as well as opportunities for collective action. Stay tuned for updates on the future development of the Retailer Green Claims Forum as well as how to get involved in shaping ideas for aligning data requests on branded green claims.
