Compostable, biodegradable, eco-friendly: what you can print on a cup

The Competition and Markets Authority chose a cup to illustrate what a misleading environmental claim looks like. If you print cups, that is worth knowing before the artwork goes to press.

The six principles

The CMA published its guidance on environmental claims in September 2021, under the Consumer Protection from Unfair Trading Regulations 2008. One thing to know before you rely on it: that guidance page still names the 2008 Regulations, and the unfair commercial practices provisions of the Digital Markets, Competition and Consumers Act 2024 apply to commercial practices from 6 April 2025 onwards. The CMA describes those provisions as replacing and updating the 2008 Regulations, and says traders can generally expect the same or similar requirements to apply. The principles below stand. The statute underneath them has moved.

Six principles run through the guidance. Claims must be truthful and accurate. They must be clear and unambiguous. They must not omit or hide important relevant information. Comparisons must be fair and meaningful. Claims must consider the full life cycle of the product or service. And claims must be substantiated.

Nothing there is exotic. What catches businesses out is the third and fifth: the information you leave off, and the part of the life cycle you skipped.

The cup example, in the CMA's own words

The guidance works through a case that maps exactly onto event drinkware. A disposable cup is marked "compostable". No further information is provided. The cup will not compost in a home compost bin, and an industrial composter is required. The CMA's conclusion is that the claim is likely to be misleading because it does not specify the circumstances.

The gap is not the word. It is the missing condition. A consumer holding that cup can only act on the claim if their local authority collects waste for industrial composting, and most of them have no way of knowing whether it does.

Why biodegradable and recyclable sit in the same bracket

The guidance treats these terms together and says they "can also be problematic. Often, they only apply to parts of products or in certain conditions."

That is the practical test for a cup. Does the claim cover the whole cup or the body without the lid? Does it hold in a home bin or an industrial facility? Does it hold in the waste system your customer can actually reach?

If the answer needs a paragraph, the paragraph belongs next to the claim.

Green, sustainable and eco-friendly

The CMA is direct about the umbrella terms: "Terms like 'green', 'sustainable' or 'eco-friendly,' especially if used without explanation, are likely to be seen as suggesting that a product... has a positive environmental impact... Unless a business can prove that, it risks falling short of its legal obligations."

Note where the burden sits. The default reading of the word is the strong one, and the business carries the job of proving it.

What this means for the artwork

Say what the cup is, say what happens to it, and say under what conditions. A reusable cup can be described by what it does, which is get used again, and that claim is easy to substantiate and hard to misread.

For anything ending in "-able", write the condition on the same panel as the claim. It costs a line of type, and it is the difference between a claim you can defend and a claim you will be asked to withdraw.

The claims that survive this test are the ones tied to what the product does. Our own page on green credentials sticks to reuse for that reason, and the single-use plastic rules are worth reading before you describe a cup as banned or compliant.