ESG Enforcement Tracker

Key facts:

The CMA launched a formal investigation into consumer group Unilever following concerns about how it markets some products, within some brands, to customers as being environmentally friendly.

Unilever owns brands such as Cif, Dove, Confort and Lynx.

The CMA’s concerns included:

• Certain statements and language used by Unilever appear vague and broad, and may mislead shoppers regarding the environmental impact of those products.
• Claims about some ingredients may exaggerate how ‘natural’ the product is, and therefore create an inaccurate or misleading impression.
• Claims focusing on a single aspect of a product may suggest it is environmentally friendly as a whole.
• Certain green claims – particularly in relation to recyclability – may be unclear, as they do not specify whether they relate to all or part of a product, or packaging.
• The use of colours and imagery – such as green leaves – may create the overall impression that some products are more environmentally friendly than they actually are.

The move was part of the CMA’s wider investigation into greenwashing.

Further, in January 2024, the CMA expanded its work on environmental claims to include fast-moving consumer goods, which are essential items used daily and repurchased regularly, such as food and drink, cleaning products, toiletries, and personal care items.

In November 2024, the CMA closed its investigation taking into account a number of factors, including changes Unilever had made to claims on some of its products and the wider impact of the CMA’s work on tackling misleading green claims.

The CMA noted that the Green Claims Code and enforcement action to date “had helped businesses understand how they can promote their green credentials whilst staying on the right side of the law”.

In closing its investigation, the CMA explained that it had not taken a view on Unilever’s compliance with consumer law.