A man kneels on a roof while laying solar PV, which the CMA has just provided greenwash guidance on

CMA publishes anti-greenwash guidelines for marketing low-carbon home technologies

The Competition and Markets Authority (CMA) has issued new guidelines to help businesses avoid misleading marketing claims when promoting low-carbon home technologies. The guidance aims to help businesses involved in promoting heat pumps, solar panels, and home insulation better understand and fulfil their obligations under consumer protection law.

Who are the CMA?

The Competition and Markets Authority (CMA) is the UK’s principle competition and consumer protection authority. The CMA ensures that businesses comply with consumer protection laws and promotes competition for the benefit of consumers, ensuring that they get a fair deal.

Why are sector guidelines needed now?

The clean tech sector, including domestic green heating, solar and insulation products, is expanding rapidly as the UK aims to meet its climate targets. The government plans to significantly increase the installations of heat pumps and solar panels in the coming years.

However, this rapid growth has led to concerns about exaggerated or misleading marketing claims, particularly around costs and eligibility for government grants. The CMA has identified these issues and introduced guidelines to protect consumers from greenwashing.

In particular, the guidance flags how headline price information and product claims found on some firms’ marketing channels were key areas of concern.

What are the new guidelines?

The new CMA guidelines state the importance of accurate and substantiated marketing claims. Key principles include:

  1. Accurate pricing
    Headline prices should include all mandatory fees and unavoidable costs like delivery and installation. If total costs can’t be calculated in advance, provide an indicative price with a clear explanation.
  2. Comprehensive costs
    Include costs for necessary works and additional products in the headline price if most consumers will need them. Clearly display prices for optional products and explain any ongoing costs.
  3. Honest claims
    Do not use deceptively low prices or inflate prices to create a false impression of discounts. Avoid including government funding in the headline price unless most consumers are eligible.
  4. Clear qualifications
    Present any important qualifications close to the headline price. Indicate that the price is subject to change and explain how the final price will be calculated after assessing the consumer’s property.
  5. Careful with government funding
    Be cautious about including government funding in the headline price. Clearly state its inclusion and eligibility criteria, and direct consumers to detailed information on the funding scheme.
  6. Transparent bundling
    When offering product bundles, do not mislead consumers about the price. If you also sell products separately, provide individual prices to help consumers understand the bundle’s value.

For more detailed guidance, businesses can refer to the official document: Marketing green heating and insulation products: Consumer law compliance advice for businesses.

Who does this guidance apply to?

This guidance applies to all businesses involved in marketing green heating and insulation products, including manufacturers, installers, and retailers of heat pumps, biomass boilers, solar panels, and home insulation.

How are these guidelines consistent with the Green Claims Code?

The CMA has clarified that the new guidelines are consistent with the Green Claims Code, which was published by the CMA in 2021. The Green Claims Code should be a reference for any claims of a product or service’s environmental benefits. It sets out best practices for making environmental claims, stating the need for accurate, clear, and substantiated statements.

Both sets of guidelines aim to prevent greenwashing by ensuring that businesses do not mislead consumers about the environmental impact or benefits of their products. Non-compliance with these guidelines can result in penalties, including fines and advertising bans.

For more information on green claims, check out our Anti-Greenwash Playbook – it’s packed with quick-fire tips that will help you transparently tell your story.

Picture of Sian Clay
Sian Clay
Sian Clay is on our client management team, specialising in ESG communications. She holds an MSc from the University of Bristol in Management in CSR and Sustainability.