A pushchair page that says “eco-friendly”, “made from recycled bottles” or “a greener choice” is making what the Competition and Markets Authority (CMA) calls an environmental claim. This guide goes through five common assumptions about such claims and answers each from the CMA’s Green Claims Code (published 20 September 2021) and its explainer on responsibility across the supply chain (published 22 January 2026). Neither document mentions prams or pushchairs; they cover goods and services generally, and the CMA says its guidance applies to businesses across the whole of the UK.
“Eco-friendly is just a friendly word”
The Code says broader, more general or absolute claims are much more likely to be inaccurate and to mislead. Terms such as ‘green’, ‘sustainable’ or ‘eco-friendly’, especially if used without explanation, are likely to be seen as suggesting a positive environmental impact, or at least no adverse impact, and unless a business can prove that, it risks falling short of its legal obligations.
It also points out that a claim of ‘environmentally friendly’ may refer to many aspects, such as air, soil and water, packaging, components, production, use and disposal, and says a high level of strong evidence is likely to be required to substantiate such a claim.
“Recycled means some of it is recycled”
According to the Code, claiming a product contains recycled content when it does not is always liable to mislead consumers. One of the fictional examples in the 2026 explainer involves a retailer that claimed all its tents were “made from recycled polyester” when not all contained recycled content and none contained above 50%. The CMA says businesses should be able to back up environmental claims with evidence, and in that example it would be more likely to act against the retailer that made the claim and had no internal process for verifying it.
Another example, in the Code, concerns a product labelled ‘recyclable’ where only the packaging could be recycled. The Code says the claim is likely to mislead people into thinking the whole product can be recycled, and is less likely to mislead if it is made clear that only the packaging is recyclable.
“If one detail is true, the claim is safe”
The Code says claims can also mislead where what they say is factually correct, if the impression given about the environmental impact, cost or benefit is deceptive. It lists the colours, pictures and logos used, and any information left out or hidden, among the aspects that may be relevant, and it warns that cherry-picking beneficial aspects and highlighting them risks misleading consumers, particularly if other aspects have a greater negative impact.
Where a claim needs further explanation, caveats or conditions should be disclosed prominently and close to the main claim; the more they are hidden in small print, the more likely consumers are to be misled.
“Only the brand answers for the claim, not the shop”
The Code says retailers who sell products carrying misleading environmental claims made by manufacturers or wholesalers on their packaging can be liable for those claims, as well as the manufacturer or wholesaler, and that retailers should assure themselves that the claims are accurate. The 2026 explainer adds that a business may be deemed to be repeating an environmental claim where it stocks a product, so the manufacturer and the retailer may both be liable for an unfair commercial practice.
It also says that, where the CMA is pursuing civil enforcement, an “innocent” or unwitting breach is still a breach, and that arguing the business took all reasonable precautions and exercised all due diligence is not a defence in civil actions. The CMA says that in deciding whom to investigate it considers which business made the claim, and that it may look at the retailer, brand, manufacturer or another business in the supply chain.
“Nothing happens if a green claim is wrong”
The 2026 explainer states that under the Digital Markets, Competition and Consumers Act 2024, which came into effect in April 2025, the CMA can decide whether consumer protection laws have been infringed, give directions on a business’s conduct and order redress to be paid to affected consumers, and can fine businesses without taking them to court. The 2021 Code was written earlier and refers to the Consumer Protection from Unfair Trading Regulations 2008. The Code adds that consumers may also bring legal proceedings or seek redress in the courts for certain breaches of consumer protection law.
The Code is not legal advice and is not exhaustive; whether a claim breaks the law depends on the circumstances, including the effects on the decisions consumers are likely to make, and the courts give the definitive interpretation.
The bottom line
On the CMA’s published guidance, a vague claim such as “eco-friendly” on a pram page needs strong evidence, a recycled claim must be true, a true detail does not make a misleading overall impression safe, and a retailer can be liable for a claim a manufacturer made. The CMA’s powers to fine and order redress under the 2024 Act came into effect in April 2025. These are the CMA’s own statements of how it reads the law, not a ruling on any particular pram or retailer.
Sources
- Making environmental claims on goods and services (Green Claims Code), Competition and Markets Authority, published 20 September 2021, read 8 November 2026 (gov.uk)
- Green claims code: making environmental claims (publication page and checklist), Competition and Markets Authority, published 20 September 2021, read 8 November 2026 (gov.uk)
- Making green claims: Getting it right, across the supply chain, Competition and Markets Authority, published 22 January 2026, read 8 November 2026 (gov.uk)