The 10% Fine: Why Greenwashing Penalties Are a Freight Problem Too

Until recently, that gap between what you say and what you can evidence often just played out as reputational fallout and a quietly rewritten webpage, but with the new UK Competition and Markets Authority CMA changes, it’s become a much bigger, board-level risk. 

If your business makes transport-related environmental claims anywhere your customers can see them (or your customers repeat them in their own comms), your freight partner isn’t just part of operations anymore, but part of your compliance exposure. 

This article explains what the “10% problem” means, how the CMA Green Claims Code applies to freight, and what you can do right now to reduce logistics greenwashing risks. 

CMA greenwashing fines UK: what’s changed? 

The CMA’s direct consumer enforcement regime sits under the Digital Markets, Competition and Consumers Act 2024. In their new guidance, the CMA sets out that monetary penalties for infringements can be up to 10% of worldwide turnover, capped at £300,000. 

That doesn’t mean every case becomes a 10% fine, but it does mean the ceiling is now high enough to be material for large businesses, and the enforcement conversation is more serious than a slap on the wrist. 

The CMA’s consumer enforcement rules came into force on 6 April 2025, and the CMA has published formal guidance on how it expects to use these powers.  

The key for business claims is that this enforcement will not only be concerned with what you say, but also what you imply and what you leave out. The burden of proof still sits with the business making the claim, even when the underlying evidence comes from suppliers. 

Why logistics is in the blast radius (even if you don’t think you’re a consumer brand) 

It’s tempting to assume that consumer law is for consumer brands, but transport and delivery claims surface everywhere: 

• on ecommerce delivery pages (‘greener delivery’, ‘carbon neutral shipping’) 

• in brand sustainability pages and annual reports 

• in retailer and customer questionnaires that ask about logistics emissions 

• in tender documents that reference sustainable transport commitments 

• in PR, thought leadership, and stakeholder updates 

Even when your product is B2B, your customers may be consumer-facing, and may use your claims as part of their own narrative. That’s how a logistics claim can snowball into reputational or regulatory exposure across a supply chain. 

Transport is such a common failure point because although sustainability teams often need to talk about Scope 3 emissions, the operational evidence is fragmented across carriers, modes, lanes, and data systems. Having a strong grasp on your actual emission data will put you in a great position for making genuine sustainability claims. 

CMA Green Claims Code: the six principles for freight and transport 

The CMA Green Claims Code is designed to help businesses comply with consumer protection law when making environmental claims. It’s built around six principles, and every one of them has a logistics-specific angle to be considered. 

1) Claims must be truthful and accurate 

If you claim low-carbon delivery, the service must be as low-carbon as you imply it is. For example, a truth of ‘we trialled an EV on one lane’ does not support ‘we deliver sustainably’ as a general statement.  

2) Claims must be clear and unambiguous 

‘Green transport’ means nothing without context. Clear claims specify what improved, by how much, over what timeframe, and for which services/lane coverage.  

3) Claims must not omit or hide important information 

If the greener option only applies to certain postcodes, service levels, or delivery windows, that limitation needs to be obvious, not buried in a footnote.  

4) Comparisons must be fair and meaningful 

‘30% lower emissions than standard delivery’ is only safe if you can explain what standard means, what boundary you used, and whether the comparison is like-for-like (same weight, same mode, same lane).  

5) Claims must consider the full life cycle 

For freight, this often translates into whether you’re accounting for the fuel and energy pathway. If you’re talking about biomethane, electricity, or alternative fuels, you need clarity on what’s being measured and what’s being assumed.  

6) Claims must be substantiated 

This is potentially the biggest consideration for logistics. Most environmental claims about transport are factual and measurable, which means you need concrete evidence that stands up to scrutiny. 

Transport greenwashing: the claims that most often create holes 

Transport is a magnet for vague language because it sits at the intersection of climate reporting, customer experience, and brand storytelling. These are the phrases that tend to create transport greenwashing risks if they aren’t tightly defined and evidenced: 

• Net zero delivery / carbon neutral shipping
  Often fails due to unclear boundaries (which legs? which lanes?), partial coverage, or an over-reliance on offsets without transparent limitations. 

• Sustainable logistics / green transport
  Often fails because it’s unquantified and undefined. What’s greener: fuel type, vehicle type, load efficiency, route optimisation, modal shift? 

• Zero-emission fleet / electric fleet
  Often fails when it’s based on pilots or a subset of vehicles, with no clarity on percentage of volume or geography covered. 

None of this is to say that progress shouldn’t be talked about. It means stop using language that implies a level of coverage and certainty if you can’t support that with figures. 

Logistics greenwashing risk: how your freight partner becomes a C-suite liability 

Although a lot of the ‘proof’ might sit outside of your direct control, your organisation is still accountable for the claims it makes. The chain usually looks something like this: 

1. Your business makes an environmental claim (whether on their website, in tender, or in a report). 
2. That claim relies on internal reporting. 
3. The internal reporting relies on supplier inputs. 
4. The supplier inputs rely on data quality, methodology, and measurement. 

If any link in that chain is weak, you end up making a claim that you can’t defend, and that’s why freight procurement has now become a governance issue. When leadership asks if you can stand behind a sustainability statement, the real question is whether your freight partners provide auditable evidence that supports your claim. 

A practical greenwashing de-risking checklist for procurement, sustainability, and legal teams 

You don’t need a six-month project to reduce risks, just a simple process that does two things: stops risky claims getting published, and upgrades the evidence behind the claims that you do make. 

Step 1: Inventory every environmental claim that touches transport 

Look for claims in: 

• delivery and returns pages 

• sustainability pages and ESG reports 

• tender responses and client questionnaires 

• PR and stakeholder communications 

Step 2: Map each claim to its data source 

For each claim, identify:

• which freight partners and lanes it relies on 

• what period it covers 

• what calculation method underpins it 

Step 3: Set minimum evidence requirements 

Agree what you need before a claim can be published. For example: 

• lane coverage thresholds (don’t claim ‘we deliver sustainably’ if it’s 5%) 

• quantified wording only when you can trace the numbers 

• documented methodology for any comparison or reduction claim 

Step 4: Put a claims approval workflow in place 

Any transport claim that is quantified, comparative, or broad should have sign-off from the right owners (sustainability and legal, as well as often finance if it’s in formal reporting). 

Step 5: Fix the weak link (usually the supplier data) 

If a claim matters commercially, upgrade the evidence behind it. That may mean: 

• formal carrier reporting requirements in contracts 

• prioritising partners who can provide primary, verifiable data, such as FSEW 

• moving away from generic averages towards shipment or lane-level reporting 

What to demand from a freight partner 

If you want to reduce logistics greenwashing risk, the fastest win is to tighten your supplier due diligence. 

Questions to ask your freight partner: 

• Is your emissions reporting primary or estimated? 

• What proportion of our volume is moved using low-carbon options, and how is that measured? 

• Can you provide lane or shipment-level reporting (rather than just monthly averages)? 

• Do you use telematics for mileage and energy/fuel inputs (particularly for electric and biomethane fleets)? 

• Can you share methodology notes and a clear audit trail for any figure you provide? 

If you can’t evidence the claim, you shouldn’t publish it. That’s the simplest line to hold, and it protects everyone internally from potential large greenwashing fines. 

How GreenFlow supports greenwash-proof transport claims 

The safest sustainability claim is the one you can prove, and that’s exactly what GreenFlow was modelled on. At FSEW, our GreenFlow decarbonisation framework is designed to close the proof gap that makes transport claims risky, by focusing on structured reporting and defensible evidence. 

If your board is asking whether your transport claims would stand up to scrutiny, start with the freight data behind them. Explore GreenFlow or get in touch to see how a provable decarbonisation approach and reporting-led logistics can help you make environmental claims that you can substantiate.