The CMA is actively investigating fashion greenwash. Here is a working guide to what claims are compliant, what is problematic, and how to substantiate the claims that matter to your customers.
The UK Competition and Markets Authority (CMA) published the Green Claims Code in September 2021 and has since opened investigations into multiple sectors — including fashion. In 2023, ASOS, Boohoo and George at ASDA were among the brands investigated. The Consumer Protection from Unfair Trading Regulations 2008 (CPRs), which the Green Claims Code enforces, can result in criminal prosecution, fines and mandatory injunctions. For a knitwear brand, the relevant question is simple: can you substantiate what you are saying, specifically and completely?
The CMA's Green Claims Code establishes six tests. A green claim is compliant only if it passes all six:
The claim must reflect the genuine environmental benefit and not overstate it. "Sustainable merino" with no certification is not truthful if you haven't verified the farming practices of your yarn supply chain. A fibre claim ("100% merino wool") is truthful if the fibre content is correct. A sustainability claim needs more.
Vague terms are problematic. "Eco-friendly", "green", "responsible" and "conscious" are unlikely to be sufficiently clear because they don't specify what benefit is being claimed. The CMA specifically flags these as potentially misleading. "Made from recycled polyester" is clear. "Eco-friendly knitwear" is not.
A claim must not omit information that would change a customer's understanding. "Made from natural fibres" applied to a jumper that is 70% recycled synthetic and 30% wool is omitting important information. Claims must reflect the whole product, not cherry-pick the best element.
If you say "more sustainable than [alternative]", the comparison must be fair, like-for-like and based on evidence. "More sustainable than fast fashion" is unlikely to be substantiated without a defined comparator and specific evidence. Comparative claims are high-risk without documented evidence of both sides of the comparison.
A claim must not focus on one stage of the product's life and ignore others. "Low-carbon shipping" that ignores the production footprint of the garment is misleading if presented as a headline sustainability claim. The claim's scope must be clear — "lower-carbon shipping [than air freight]" is scoped; "sustainable supply chain" is not, and requires full life-cycle evidence.
You must hold evidence for any claim before you make it — not after being challenged. Third-party certifications (OEKO-TEX, GOTS, RWS, ZQ) provide substantiation. Test certificates, audit reports, and certified data are substantiation. Brand assertions without documentation are not.
| Claim | Status | Why |
|---|---|---|
| "100% merino wool" | ✓ Compliant | Fibre composition claim — verifiable by test, required by UK Textile Regulations |
| "Made in Türkiye" | ✓ Compliant | Origin claim — verifiable against EUR.1 customs documentation |
| "OEKO-TEX certified yarn" | ✓ Compliant with certificate | Third-party certification held; must be able to produce the certificate on request |
| "Mulesing-free merino" | ✓ Compliant with ZQ/RWS evidence | Verifiable via certified supply chain; not compliant without documentation |
| "Natural fibre knitwear" | ✓ Compliant if accurate | Descriptive claim; accurate if the garment is natural-fibre only |
| "Eco-friendly knitwear" | ⚠ Problematic | Vague; no defined benefit; likely CMA-flagged per Green Claims Code principle 2 |
| "Sustainable fashion" | ⚠ Problematic | Lacks specificity; no defined claim; CMA specifically names "sustainable" as a vague term |
| "Conscious collection" | ⚠ Problematic | No defined meaning; decorative sustainability language; similar to ASOS's investigated claims |
| "Sustainably sourced cashmere" | ⚠ Problematic without evidence | What does "sustainably sourced" mean for cashmere? Without SFA or equivalent certification, unverifiable |
| "Lower carbon footprint than China" | ⚠ High risk | Comparative claim requiring documented LCA data for both supply chains; very difficult to substantiate accurately |
| "Carbon neutral" | ⚠ High risk | Requires verified carbon accounting across Scope 1, 2, 3 emissions and third-party verification |
| "Ethically made" | ⚠ Problematic without audit | Requires third-party social audit (SMETA 2-pillar or equivalent); not substantiated by factory assurance alone |
OEKO-TEX STANDARD 100 certifies that the textile has been tested for harmful substances and is within limits. It covers chemicals, dyes, heavy metals and other restricted substances. It substantiates a claim that the product is free from harmful substances. It does NOT substantiate environmental impact, carbon footprint, or ethical labour practice claims. What you can say: "Tested for harmful substances to OEKO-TEX STANDARD 100." What you cannot say: "Sustainable, as certified by OEKO-TEX."
RWS covers mulesing, animal welfare practices and land management at the farm level, with chain of custody through processing. It substantiates welfare-related claims about the wool. What you can say: "RWS-certified wool — verified animal welfare standards." What you cannot say: "RWS-certified means our whole supply chain is ethical" — RWS only covers the wool sourcing stage.
GOTS covers organic fibre, chemical processing, and social criteria through the supply chain. A GOTS-certified garment provides one of the strongest substantiated sustainability claims available to a knitwear brand. What you can say: "Certified organic wool to GOTS standard." Conditions: the garment (not just the yarn) must be GOTS-certified; the manufacturer must hold GOTS certification.
A SMETA (Sedex Members Ethical Trade Audit) 2-pillar or 4-pillar audit verifies labour standards, health and safety at the factory. It substantiates claims about factory working conditions. What you can say: "Manufactured at a SMETA-audited factory." What you cannot say: "Fully ethical supply chain" — SMETA covers the factory only, not the wider yarn or trim supply chain.
Natural fibre (100% wool, merino, cashmere) is verifiable from the fibre test. Country of origin (Made in Türkiye) is verifiable from the EUR.1. These are the foundation of a legitimate product story — they are also genuinely more meaningful than vague sustainability language. Lead with what you can prove. Add certification claims only as you acquire the certifications.
"The yarn in this garment is certified to OEKO-TEX STANDARD 100" is scoped to the yarn. "Our factory holds a valid SMETA 2-pillar audit" is scoped to the factory. Scoped claims are more defensible than sweeping ones. "We source responsibly" is not scoped. "Our merino yarn is sourced from RWS-certified farms" is scoped and substantiatable if true.
The CMA's standard is that evidence must exist at the time the claim is made, not acquired in response to a challenge. Before any green claim goes live on your website or in marketing materials, hold the supporting documentation: certificate number, expiry date, certification body. Store this in a compliance file. If you are asked to evidence a claim, you can produce it immediately.
A GOTS certificate has an annual renewal cycle. An OEKO-TEX certificate covers specific product batches. As your supply chain changes (new factory, new yarn source), your substantiation documents may need updating. Schedule an annual review of all sustainability claims on your website against current documentation. A claim that was accurate last year may be unsupported this year if the certificate has lapsed or the supply chain has changed.
We supply OEKO-TEX STANDARD 100 yarn certificates, factory audit documentation, and fibre test certificates as standard. We can support RWS-certified merino yarn requests. We do not ask you to take our word for it — we document everything we claim.
Official Sources
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