Green Claims Compliance
Reputation &
compliance
The eco toilet paper category is full of claims that sound good but have no published evidence behind them.
"Planet friendly." "Eco-friendly." "Sustainable." Brands put them on packaging, in ads, across social, and hope nobody asks to see the data.
Naked Paper (then Naked Sprout) was facing press scrutiny over its green claims. The product was genuinely the most sustainable on the UK market, but the evidence architecture wasn't there to defend it yet.
That's a dangerous position for any brand making environmental claims in a category where the CMA is actively expanding its scrutiny, especially when the press come calling. Which is why they hired us.
"Planet friendly." "Eco-friendly." "Sustainable." Brands put them on packaging, in ads, across social, and hope nobody asks to see the data.
Naked Paper (then Naked Sprout) was facing press scrutiny over its green claims. The product was genuinely the most sustainable on the UK market, but the evidence architecture wasn't there to defend it yet.
That's a dangerous position for any brand making environmental claims in a category where the CMA is actively expanding its scrutiny, especially when the press come calling. Which is why they hired us.
The
Work
We conducted a full Green Claims Audit across Naked Paper's digital presence and on-pack copy, identifying every environmental claim being made and aligning each one against the relevant regulatory frameworks - the CMA's Green Claims Code, ASA guidance on environmental claims, and CAP's rules on misleading advertising.
Each claim was risk-graded using our bespoke ranking system, then mapped against the evidence Naked Paper already held - scientific test results, ISO certifications, lifecycle assessments, factory audits, supply chain documentation. Where the evidence existed, we identified how it needed to be presented to meet compliance standards. Where gaps remained, we flagged what additional proof was required.
We wrote the compliant claims, advised on how to deploy them in advertising, and built the green credentials evidence page - a comprehensive, publicly accessible resource linking every claim to its proof.
They also needed to substantiate comparative claims that their product was greener than the competition. We conducted a detailed competitor analysis across eight rival brands, auditing their publicly available evidence across accreditations, packaging, climate footprint, factory operations, supply chain, and raw materials. Where competitors claimed sustainability credentials without published proof, we documented the gap. This became the foundation for the comparison tables now live on their site. Every claim Naked Paper makes about outperforming the competition is anchored to verifiable, published data, not marketing opinion.
When the brand rebranded from Naked Sprout to Naked Paper, we conducted a secondary audit to ensure all claims remained compliant under the new identity.
Each claim was risk-graded using our bespoke ranking system, then mapped against the evidence Naked Paper already held - scientific test results, ISO certifications, lifecycle assessments, factory audits, supply chain documentation. Where the evidence existed, we identified how it needed to be presented to meet compliance standards. Where gaps remained, we flagged what additional proof was required.
We wrote the compliant claims, advised on how to deploy them in advertising, and built the green credentials evidence page - a comprehensive, publicly accessible resource linking every claim to its proof.
They also needed to substantiate comparative claims that their product was greener than the competition. We conducted a detailed competitor analysis across eight rival brands, auditing their publicly available evidence across accreditations, packaging, climate footprint, factory operations, supply chain, and raw materials. Where competitors claimed sustainability credentials without published proof, we documented the gap. This became the foundation for the comparison tables now live on their site. Every claim Naked Paper makes about outperforming the competition is anchored to verifiable, published data, not marketing opinion.
When the brand rebranded from Naked Sprout to Naked Paper, we conducted a secondary audit to ensure all claims remained compliant under the new identity.
Naked Paper now has one of the most transparent and defensible evidence pages in UK FMCG, with every single claim linked to verifiable proof.
The brand doesn't just say it's the UK's most sustainable toilet roll. It can show you exactly why - claim by claim, competitor by competitor, certificate by certificate. And it can use those claims in advertising, on pack, and under press scrutiny, with confidence.
In 2025, Naked Paper won a King's Award for Enterprise in Sustainable Development - the highest official recognition a UK business can receive for its environmental impact.
The brand doesn't just say it's the UK's most sustainable toilet roll. It can show you exactly why - claim by claim, competitor by competitor, certificate by certificate. And it can use those claims in advertising, on pack, and under press scrutiny, with confidence.
In 2025, Naked Paper won a King's Award for Enterprise in Sustainable Development - the highest official recognition a UK business can receive for its environmental impact.