Writing an environmental claim used to mean picking accurate wording. Under EPR fee modulation, Green Claims Code enforcement and PPWR all landing in the same year, an environmental label now has to be accurate, evidenced and consistent with a fee category the business may not have fully understood when the claim was written. For environmental labels, that is a considerably higher bar than wording alone.
This article looks at why environmental claims have become harder to write correctly, and what businesses need in place before making one.
Why Wording Alone Is No Longer Enough
An environmental claim now sits inside three separate regulatory checks at once. Green Claims Code enforcement expects evidence behind any sustainability statement, EPR’s RAG rating system independently assesses whether a material is genuinely recyclable in current UK infrastructure, and PPWR adds its own recyclability and substance requirements for anything sold into the EU. A claim can be technically true and still create risk if it implies a fee category or recyclability status the packaging does not actually hold, since a green sounding label on red rated packaging is now a visible mismatch rather than a private compliance detail. That mismatch is easier for a regulator, a retailer or a customer to spot than it was even a year ago, since RAG ratings are increasingly referenced publicly alongside the products they describe.
What This Means for Environmental Labels
Businesses writing environmental claims are increasingly checking their RAG rating before finalising label wording, rather than treating the claim and the fee category as separate conversations handled by different teams. That alignment matters because a claim that overstates a material’s recyclability is now easier to spot and challenge than it was before RAG ratings became public reference points tied directly to cost.
A Red Rating Now Undoes Any Green Claim
Discussion among sustainability and packaging teams has increasingly focused on the gap between marketing language and RAG reality, with several businesses reporting internal reviews specifically to check that existing environmental claims still hold up now that a red or green rating sits publicly alongside them. There is growing recognition that a claim written before RAG ratings existed may no longer read as accurate once a fee category makes the underlying material performance visible.
An environmental claim that contradicts a public fee rating is no longer a private inconsistency, it is a visible one. Businesses writing to match their rating rather than their ambitions are the ones protecting themselves from a challenge that used to be hard to make and is now simple to check.