Environmental claims have become an increasingly important part of packaging communications. But claims such as “recyclable”, “sustainable” and “eco-friendly” can expose businesses to greenwashing risks if they are vague, misleading or unsupported by evidence.
The introduction of an explicit reference to the Green Claims Code within the Recyclability Assessment Methodology (RAM) for 2027 brings these issues closer together.
Although a RAM rating does not automatically validate a recyclability claim, the underlying assessment could provide important evidence to support it – or highlight where further explanation and qualification are required.
Recyclability assessments should therefore not be viewed solely as an Extended Producer Responsibility reporting exercise. The data used to determine a packaging item’s RAM rating could also help producers communicate recyclability more confidently.
This article explains what greenwashing is, how the Green Claims Code applies to packaging and what the new connection with RAM 2027 could mean for producers.
What Is Greenwashing?
The Cambridge Dictionary defines greenwashing as behaviour or activities “that make people believe that a company is doing more to protect the environment than it really is”[1].
Greenwashing occurs when a business gives consumers a misleading impression of the environmental performance of a product, service or organisation.
This does not only include claims that are completely false. A statement may contain technically correct information and still be misleading because of:
- Information that has been omitted
- Vague or poorly defined language
- Imagery, colours or symbols that create an exaggerated impression
- A claim applying to only one component when consumers may believe it applies to the whole product
- Environmental benefits being presented without important conditions or limitations
Packaging is particularly exposed to this risk. Claims such as “recyclable”, “sustainable”, “eco-friendly” or “better for the environment” can appear straightforward, but they may conceal significant complexity.
For example, packaging may be technically capable of being recycled under laboratory or specialist conditions without being commonly collected, sorted or reprocessed through the UK’s operational recycling system. Similarly, one component may be recyclable while another attached component prevents the complete packaging item from being proceeded effectively.
What Is the Green Claims Code?
The Competition and Markets Authority’s (CMA) Green Claims Code helps businesses understand how consumer protection law applies to environmental claims.
The Code sets out six central principles. Environmental claims should:
- Be truthful and accurate
- Be clear and unambiguous
- Not omit or conceal important information
- Make fair and meaningful comparisons
- Consider the full life cycle of the product or service
- Be supported by evidence
These principles apply to claims made through advertising, websites, branding and product packaging.
Responsibility can also extend across the supply chain. The CMA’s latest green claims guidance for supply chains makes clear that manufacturers, brands, wholesalers and retailers must all take appropriate steps to ensure that environmental claims they make or repeat are accurate and not misleading.
A recyclability claim must therefore reflect what can realistically happen to the packaging in practice. The CMA specifically warns businesses against describing a product as recyclable where it is not, or where non-recyclable components prevent the overall item from being recycled. Businesses should also make clear whether a claim relates to the product, its packaging or only a particular component.
The consequences of getting this wrong are significant. Under the UK’s strengthened consumer protection regime, the CMA can directly investigate breaches and impose penalties of up to £300,000 or, if higher, 10% of a business’s turnover.
Alongside financial penalties, businesses may face:
- Requirements to amend or withdraw claims
- Reputational damage
- Complaints to the Advertising Standards Authority
- Loss of consumer and customer confidence
- Increased scrutiny of other environmental statements
What Is Greenhushing?
At the opposite end of the spectrum is “greenhushing”: deliberately limiting communication about genuine environmental improvements because of concerns about regulatory scrutiny or accusations of greenwashing.
For packaging producers, excessive caution could mean avoiding recyclability claims even where packaging has been carefully redesigned and performs well through the recycling system.
The objective should not be to stop communicating environmental improvements, but to make claims that are specific, proportionate and supported by credible evidence.
The CMA recognises that businesses can benefit from promoting genuine environmental improvements, provided their claims are clear, accurate and not misleading. Credible claims can build consumer confidence while encouraging businesses to compete and innovate on environmental performance.
How RAM 2027 Brings Green Claims Into the Conversation
RAM 2027 must be used by large producers to assess and report the recyclability of household packaging supplied during the 2027 reporting year.
Packaging is assessed across four stages:
- Collection
- Sortation
- Reprocessing
- Application
The methodology focuses on what happens in practice within the UK’s existing operational recycling infrastructure, rather than whether packaging is merely technically recyclable.
To claim that packaging is “recycled at scale” for RAM purposes, producers must have evidence that the packaging moves through all four stages using existing, proven infrastructure, rather than pilot or experimental systems.
The RAM Assessment produces one of three RAG ratings:
- Red: The packaging has characteristics that make it difficult to recycle at scale or cannot reliably move through the existing recycling systems.
- Amber: The packaging faces limitations or requires specialist collection, sortation or reprocessing arrangements.
- Green: The packaging is widely recyclable through current UK infrastructure.
For the first time, the RAM overview contains a specific section on green claims. It directs producers to consider relevant CMA guidance, including the Green Claims Code, when making packaging decisions based on RAM ratings.
This does not mean that RAM has become a packaging-labelling standard. The guidance expressly states that RAM ratings are not related to other recyclability labels that may appear on packaging.
Nor does a RAM rating automatically determine whether a particular environmental claim is lawful. Claims must still be considered in their full context, including their wording, presentation, qualifications and the overall impression they are likely to give consumers.
However, the inclusion of the Green Claims Code makes an important connection: a producer’s regulatory assessment of recyclability could be highly relevant when determining whether a recyclability claim can be substantiated.
The Risks of Calling Red-Rated Packaging Recyclable
An unqualified recyclability claim made about Red-rated packaging could create a clear area of risk.
A Red rating indicates that the packaging has failed to meet the RAM criteria at one or more stages of the existing UK recycling system. Packaging meeting an automatic-Red criterion cannot be considered recyclable at scale for EPR purposes, even where it may be technically recyclable under different or highly specialised conditions.
Describing that packaging simply as “recyclable” may therefore be difficult to reconcile with the producer’s own regulatory assessment.
This does not necessarily mean that every claim relating to the packaging would be misleading. However, the producer would need robust evidence explaining the recycling route concerned, any relevant limitations and whether consumers can realistically access that route.
A general, unqualified claim could be particularly difficult to defend where the producer has already reported that the packaging is not recyclable at scale under RAM.
Amber-rated packaging will also require careful consideration. An Amber rating does not necessarily mean that a recyclability claim can never be made, but the claim may need clear qualification.
For example, packaging may depend on a qualifying take-back scheme rather than household recycling, or face other limitations within the collection, sortation, reprocessing or application stages. Any instructions or conditions should be clear, prominent and positioned close to the claim.
Using Green Ratings To Communicate With Confidence
The Green Claims Code should not prevent producers from talking about genuinely recyclable packaging. Used correctly, RAM 2027 could help businesses replace vague environmental marketing with specific, credible and evidence-led communications.
A Green rating provides a structured assessment indicating that the packaging meets the RAM criteria across every relevant stage of the UK recycling system. This could form an important part of the evidence supporting a specific recyclability claim.
However, a Green rating should not be treated as a blanket endorsement of the packaging’s wider environmental performance. It does not, for example, automatically substantiate broader claims such as “sustainable”, “environmentally friendly” or “better for the planet”.
Businesses that invest in reliable packaging data, transparent reporting and evidence-led design will be better placed to reduce greenwashing risks, avoid unnecessary greenhushing and communicate genuine improvements with greater confidence.
How RAM Assess Can Help
Making credible recyclability claims starts with having reliable packaging data and a clear understanding of how every component performs under RAM. This is where Clarity’s RAM Assess platform can help.
RAM Assess automates component-level assessments across packaging portfolios, generating clear Red, Amber and Green ratings and highlighting the materials or formats responsible for poorer results.
The platform can help businesses:
- Identify packaging that may present a higher risk when making recyclability claims
- Understand the components or materials affecting each RAM rating
- Explore opportunities to improve packaging recyclability
- Forecast the potential effect of RAM ratings on modulated EPR disposal fees
- Create a structured evidence base to support internal packaging decisions and the review of external recyclability claims
By providing a clear, data-led view of packaging recyclability, RAM Assess can help producers identify where environmental claims may require further evidence or qualification – and where strong assessment results could support more confident communication.
Find out more about RAM Assess: Explore RAM Assess
[1] https://dictionary.cambridge.org/dictionary/english/greenwashing
