Rules and ethics
Part of Eco-friendly promotional products UK: what to ask suppliers before you order
Eco-friendly promotional products UK: what to ask suppliers before you order
Eco-friendly promotional products UK: the questions to ask suppliers about recycled content, UKCA, UK REACH and the CMA Green Claims Code before you order.
What to take away
- Ask for evidence per material, not per productrecycled content percentages, chain of custody, and the name of the certifying body.
- Environmental claims must be backed by evidence you can show; the CMA's Green Claims Code applies to branded merchandise as much as to retail.
- UKCA marking and UK REACH cover safety and chemicals, not sustainability, so do not accept them as green proof.
- Get the supplier to confirm the production lead time, minimum order quantity for each design or colour, and end-of-life route in writing before you pay a deposit.
- Unsold stock and returns remain waste, so plan disposal under your duty of care.
The claim carries more risk than the product
Most environmental trouble in this category starts with the wording on the artwork, not the item itself. A bamboo pen is still a pen. Call it planet-friendly without evidence and you have made a claim you must prove.
The Competition and Markets Authority published its Green Claims Code in September 2021 and has continued to review green claims since. The code asks for claims that are truthful and complete, and backed by evidence you hold before publication. The CMA's work on green claims sits alongside its wider consumer protection role. For advertising claims, the Advertising Standards Authority (ASA) can also apply the CAP Code, including its rules on environmental claims.
Blanket phrases such as 100% sustainable are the quickest route to a complaint. Regulators read the whole impression, including colour, imagery and the small print on the reverse of a card. Words like eco and green carry little weight on their own.
What to ask for, claim by claim
Take the sentence you intend to print and match it to one document. If a supplier cannot name the document, treat the claim as unproven.
Claim vs evidence to request
Claim on artwork
- Made from recycled plastic
- Post-consumer recycled content percentage
- Organic cotton
- Certificate number and issuing body
- Biodegradable
- Test standard and assumed conditions
- Carbon neutral
- What was measured, residual emissions
- Recyclable
- Material and local collection route
Evidence to request
- Made from recycled plastic
- Pre-consumer scrap counted as recycled
- Organic cotton
- Mill or finished garment covered
- Biodegradable
- Item will meet those conditions
- Carbon neutral
- Offsets replace a reduction
- Recyclable
- Council actually collects it
What to check
- Made from recycled plastic
- Organic cotton
- Biodegradable
- Carbon neutral
- Recyclable
What to ask for
| Claim on the artwork | Evidence to request | What to check |
|---|---|---|
| Made from recycled plastic | Post-consumer recycled content percentage and a supplier declaration | Whether pre-consumer scrap is being counted as recycled |
| Organic cotton | Certificate number and the issuing body | Whether the certificate covers the mill or the finished garment |
| Biodegradable | The test standard and the conditions it assumes | Whether the item will ever meet those conditions |
| Carbon neutral | What was measured, and how residual emissions were handled | Whether offsets replace a reduction you could have made |
| Recyclable | The material and your local collection route | Whether your council actually collects it |
For a biodegradable or compostable packaging claim, ask for the test report and evidence against EN 13432. That standard concerns packaging; it is not proof that any finished promotional item will biodegrade in ordinary conditions.
Certificates are usually issued to a factory or a mill, not to a brand. Ask which site the certificate covers before you accept it for a finished product.
Before you accept any badge, read what the main sustainability certifications actually mean. For example, the Global Organic Textile Standard (GOTS) covers organic textiles, the Global Recycled Standard (GRS) covers recycled content, and Forest Stewardship Council (FSC) chain-of-custody certification can apply to paper and wood. OEKO-TEX STANDARD 100 concerns harmful substances in textiles; it is not, by itself, proof of recycled content or a broad environmental benefit. Ask for the certificate number and check its holder, site, scope and validity with the scheme or certification body.
UKCA, UK REACH and the safety paperwork
Two sets of rules often get confused with sustainability. UKCA marking covers product safety for goods in scope of specific regulations. UK REACH covers chemical substances, including some inks and coatings. Northern Ireland follows different arrangements for many of these goods.
Neither is proof of an environmental benefit. A supplier who offers them as green credentials has answered a different question. Ask separately about material, process and end of life.
When the campaign ends, the pens, bottles and bags you cannot reuse become waste. The Environmental Protection Act 1990 sets the duty of care that follows your stock when it leaves your premises, including handovers to a waste carrier. In England, check the carrier on the Environment Agency's public register of waste carriers, brokers and dealers before handing over the waste; elsewhere in the UK, check the equivalent register with the relevant environmental regulator.
The GOV.UK environment topic page gathers current guidance on packaging and waste, which is worth checking before you brief a supplier on a new gift box.
Where the environmental benefit actually sits
The largest gains usually come from ordering fewer, better items and keeping them in use. A reusable bottle carried for two years is a stronger story than three cheap ones replaced annually.
Longevity, refills and spare parts are easier to evidence than abstract carbon claims. Ask whether the item can be refilled or repaired, and price the refill alongside the first order.
A short sequence for the buying conversation
Work through these five steps before you sign anything:
- Define the claim.Record the exact wording, product and material it refers to.
- Ask for evidence.Match each claim to a document, such as a material breakdown, test report or certificate; note the certificate number, holder, site and scope.
- Check the claim and credentials.Verify certificates with the named scheme or certification body, and ask for EN 13432 test evidence for biodegradable or compostable packaging claims.
- Separate green claims from safety checks.Ask which regulations apply to the product and request the relevant UKCA and UK REACH paperwork where applicable.
- Put the order terms in writing.Confirm the specification, production lead time, delivery date, minimum order quantity for each design or colour, price at your actual quantity, and any end-of-life route or take-back arrangement.
Five steps before you sign
- Write exact sentence and evidence needed
- Ask certificates by material and factory
- Check certificate numbers with issuing body
- Ask who handles overruns and disposal
- Put evidence and rules in purchase order
The same discipline applies to any custom project, so the checks before ordering are worth running through with each new supplier.
Keep the email trail. If a claim is questioned later, the paperwork you hold is your defence, not the supplier's website.
Common questions
Do eco-friendly promotional products cost more?
Often, though the gap narrows at higher volumes. There is no single price for every item: ask for a unit price at your real quantity rather than a headline rate quoted at 5,000 units, and compare like-for-like quotes for the same specification and branding.
Can I call a product carbon neutral?
Only if you can show what was measured, for which product or activity, and over what period, as well as how emissions were reduced and residual emissions addressed. Ask which standard the supplier used, such as ISO 14068-1, and request the supporting calculation and evidence for any offsets. Keep the evidence for as long as the claim runs.
Does branded merchandise need UKCA marking?
Only where the product falls inside a safety regime that requires it, such as toys, electricals or personal protective equipment. Ask the supplier which regulations the item is in scope of, and get that in writing.
