waste-claims

---
name: waste-claims
description: Takes every environmental claim your business makes, on the menu, the window, the website, the delivery app and the social bios, and returns each one either evidenced and safe to keep, rewritten to say what you can actually prove, or struck with the rule that strikes it. Use before you print a menu or a sign, when a supplier gives you a badge to display, or when somebody in the business wants to put the word sustainable on something.
---

# Say you are doing the right thing, without a ruling published under your own name

You give this every place your business says something environmental, plus whatever evidence sits behind each claim. You get back one dated file: each claim quoted exactly as it appears, tested against the six published principles and the advertising rules, with the evidence named or the gap named; the claims that must go, with the rule that removes them; the claims that survive, rewritten; and the enforcement position as it now stands. It does not approve your marketing. It applies published rules to your own words and shows the working.

## What it does

1. **Collect every claim first, from every surface, because the regulator judges the impression and not the sentence.** Menu, specials board, window vinyl, table talker, till receipt, website footer, About page, Instagram bio, delivery app listing, van livery, the badge on the door, the line in your email signature. Quote each exactly as it appears, with a photograph or screenshot and the date. The CMA's guidance applies to "all businesses who make environmental claims", and its six principles are the frame the whole file uses: "Claims must be truthful and accurate", "Claims must be clear and unambiguous", "Claims must not omit or hide important information", "Comparisons must be fair and meaningful", "Claims must consider the full life cycle of the product or service", and "Claims must be substantiated". A claim you forgot about is still a claim, and the window vinyl outlives three menu reprints.

2. **Strike anything whose meaning a customer could not state back to you, because vagueness is the most common failure and the cheapest to fix.** CAP Code rule 11.2 is one line: "The meaning of all terms used in marketing communications must be clear to consumers." The CMA has named the words. In the undertakings it secured from ASOS, Boohoo and George at Asda on 27 March 2024, statements about materials had to be "specific and clear, such as 'organic' or 'recycled', rather than ambiguous - e.g., using terms like 'eco', 'responsible', or 'sustainable' without further explanation." So "sustainably sourced", "eco-friendly", "planet-friendly", "responsible" and "green" all fail on their own. Each is rescued the same way, by naming the specific thing: not "sustainable seafood" but the certification and the species, not "eco packaging" but the material and what happens to it.

3. **Test every absolute claim against the evidence you hold today, and downgrade it to a comparative one if you cannot.** Rule 11.3: "Absolute claims must be supported by a high level of substantiation. Comparative claims such as 'greener' or 'friendlier' can be justified, for example, if the advertised product provides a total environmental benefit over that of the marketer's previous product or competitor products and the basis of the comparison is clear." Plastic-free, zero waste, carbon neutral, 100% recyclable and fully compostable are absolutes and each needs a document. The CMA's unfair commercial practices guidance names the material information: "the basis on which a trader makes a claim that a product is 'greener', including what is meant by the term 'greener' and what the product is 'greener' than." A comparative claim with no stated comparator is not a safer absolute claim, it is a different failure.

4. **Check whether the claim covers the whole thing or one part of it, and say which.** Rule 11.4: "Marketers must base environmental claims on the full life cycle of the advertised product, unless the marketing communication states otherwise, and must make clear the limits of the life cycle. If a general claim cannot be justified, a more limited claim about specific aspects of a product might be justifiable. Marketers must ensure claims that are based on only part of the advertised product's life cycle do not mislead consumers about the product's total environmental impact." In a venue this bites on packaging above all. A cup whose liner is compostable only in an industrial facility that does not serve your postcode is not a compostable cup to the person holding it, and a box called recyclable when your own collector puts it in general waste is a claim about the material rather than the outcome. State the limit inside the claim or make the claim smaller.

5. **Delete every claim that takes credit for something the law already requires, and every claim that flags the absence of something nobody uses.** Rule 11.7: marketing communications "must not mislead consumers about the environmental benefit that a product offers; for example, by highlighting the absence of an environmentally damaging ingredient if that ingredient is not usually found in competing products or by highlighting an environmental benefit that results from a legal obligation if competing products are subject to that legal obligation." This is the rule hospitality breaches most often and least deliberately. In England the supply of single-use plastic cutlery, drinks stirrers and expanded and extruded polystyrene food and drink containers is banned outright, so every other venue has stopped too. "We've gone plastic cutlery free" is not a claim, it is compliance with a ban, and presenting it as a choice implies a benefit competitors do not offer.

6. **Put the basis of any carbon claim inside the claim, not behind a link.** The ASA's ruling on BrewDog plc, published 20 December 2023 under reference G23-1210353, is the case to show anybody who thinks a link will do. The ad was an Instagram post carrying "BEER FOR YOUR GRANDCHILDREN" with a "Positive Planet CERTIFIED CARBON NEGATIVE COMPANY" badge. The complaint, as the ruling records it, was that "Two complainants challenged whether the ad was misleading because it failed to make the basis of the carbon negative claim clear." BrewDog argued that Instagram did not permit links in the caption and that directing consumers to the bio link was standard practice given "space and functionality constraints". The ASA upheld it: "Without that information, we considered that consumers would not have sufficient information to understand the basis of the environmental claims in the ad." The certification badge did not save it either, because it "did not provide information in the ad on the basis for the 'carbon negative' claim". The ad breached rules 3.1, 3.3 and 11.1, and the ASA "told Brewdog Plc to ensure the basis of environmental claims was clear in future ads". Rule 11.1 is the short version: "The basis of environmental claims must be clear. Unqualified claims could mislead if they omit material information."

7. **Audit the badges, marks and memberships on your door and your menu, because two of the failures here are banned practices with no defence.** The CMA's unfair commercial practices guidance lists among banned practices "Displaying a trust mark, quality mark or equivalent without having obtained the necessary authorisation" and "Claiming to be a signatory to a code of conduct when the trader is not." The CMA's undertakings add the scope point: "Statements made by the companies about accreditation schemes and standards must not be misleading. For example, statements must make clear whether an accreditation applies to particular products or to the firm's wider practices." So for each logo on display: who issued it, is the authorisation current, what does the certificate say, and does it cover the thing you have put it next to. A supplier's certification usually covers the supplier's product and not your kitchen, and a membership that lapsed two years ago is still on the window.

8. **Rewrite the survivors so that each one says the specific, provable thing, and keep the evidence with the wording.** For every claim that stays, write three lines: the exact wording that will appear, the document that evidences it with its date and issuer, and the surface it appears on. A claim with no document does not become a caveat, it becomes a smaller claim or it goes. The regulator's test is the average consumer, "reasonably well informed, reasonably observant and reasonably circumspect", and whether the practice is likely to cause a transactional decision, which includes "the purchase or supply of a product (including whether, how or on what terms to make the purchase or supply)". Somebody choosing your restaurant over the one next door because of a word on the window has made a transactional decision.

9. **Record the enforcement position, date the file, and fix a review date tied to your next print run.** The unfair commercial practices provisions in the Digital Markets, Competition and Consumers Act 2024 "apply to commercial practices which happen from 6 April 2025 onwards", replacing and updating the Consumer Protection from Unfair Trading Regulations 2008. From that date the CMA "will now be able to decide whether consumer protection laws have been infringed (rather than litigating through the courts) and to tackle any breaches directly and proportionately, including through consumer redress and fines", with penalties of up to 10% of global turnover. Trading standards can act locally, and the ASA can rule on your advertising and publish the ruling under your own name, which for an independent venue is usually the outcome that actually hurts. Date the file, record when each source was read, and review it whenever a menu, a sign or a listing is next reprinted.

## Then it checks

1. Every claim in the file is quoted exactly as it appears, with the surface it appears on, a photograph or screenshot reference and the date it was captured, and no claim is paraphrased.
2. Every claim is tested against all six of the CMA principles by name, and the file records which principle each struck claim failed.
3. No surviving claim uses eco, sustainable, responsible, green, planet-friendly or environmentally friendly on its own, without the specific thing it stands for stated in the same sentence.
4. Every surviving absolute claim names a document with an issuer and a date, and every surviving comparative claim states what it is being compared with.
5. No surviving claim presents compliance with a legal ban or requirement as a benefit, and any claim about the absence of a material states whether competitors are under the same obligation.
6. Every badge, mark or membership on display is listed with its issuer, the current status of the authorisation and what it covers, and the file states nowhere that the claims comply or that the business is safe from enforcement.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is. A claim written as though the chef or the owner said it goes to that person for approval before it appears anywhere.
- Never write a claim the business cannot evidence today with a document it holds. A substantiation that is being arranged, promised by a supplier or believed to exist is a gap with a name and a date against it, not a claim with a caveat.
- Refuse to write, soften or rephrase any claim that presents compliance with a legal requirement as an environmental choice, however the business asks for it. That is the failure rule 11.7 names and it is the one a competitor will report.
- Never state a percentage of waste diverted, a carbon figure, a recycling rate or a saving the business has not measured and cannot show the working for. A number in a claim is the most checkable thing in it and the most expensive to get wrong.
- Never tell an owner that a claim is compliant, approved or safe to publish. Those are matters for the ASA, the CMA, trading standards and the owner's solicitor, and an owner told "you are fine" stops asking the people who could actually tell them.
- Never reinstate a struck claim in a later file. Struck claims read well, which is exactly why they were struck, and they reappear at the next menu reprint unless the file says why they went.
- This output is a working document prepared for the owner to check against their own certificates, supplier documents and contracts, and for their solicitor or trade body to check any comparative, absolute or superlative claim, before anything is printed or published. It applies published rules to draft copy. It is not legal advice and it is not a ruling that the copy complies.

## Built from
- Competition and Markets Authority, "Making environmental claims on goods and services", part of the Green Claims Code, https://www.gov.uk/government/publications/green-claims-code-making-environmental-claims/environmental-claims-on-goods-and-services, published 20 September 2021, read 16 September 2026: the six principles quoted in step 1, the statement that the guidance applies to all businesses making environmental claims, and its basis in the Consumer Protection from Unfair Trading Regulations 2008 and the Business Protection from Misleading Marketing Regulations 2008.
- Committee of Advertising Practice, CAP Code (Edition 12), Section 11 "Environmental claims", https://www.asa.org.uk/type/non_broadcast/code_section/11.html, no publication date shown on the page, with rules 11.8 and 11.9 shown as deleted on 24 October 2025, read 16 September 2026: rule 11.1 in step 6, rule 11.2 in step 2, rule 11.3 in step 3, rule 11.4 in step 4 and rule 11.7 in step 5, and the background note that marketers "should take account of the Green Claims Code published by the Competition and Markets Authority".
- Advertising Standards Authority, "ASA Ruling on BrewDog plc", complaint reference G23-1210353, https://www.asa.org.uk/rulings/brewdog-plc-g23-1210353-brewdog-plc.html, published 20 December 2023, read 16 September 2026: the worked example in step 6 of a carbon claim upheld as misleading because the basis was behind a link rather than in the ad, and the rules breached.
- Competition and Markets Authority, "Unfair commercial practices" (CMA207), https://www.gov.uk/government/publications/unfair-commercial-practices-cma207/unfair-commercial-practices, published 18 November 2025, last updated 18 November 2025, read 16 September 2026: the 6 April 2025 application date in step 9, the "greener" material information example in step 3, the average consumer and transactional decision tests in step 8, and the banned practices on trust marks and codes of conduct in step 7.
- GOV.UK and the Competition and Markets Authority, "Green claims: CMA secures landmark changes from ASOS, Boohoo and Asda", https://www.gov.uk/government/news/green-claims-cma-secures-landmark-changes-from-asos-boohoo-and-asda, published 27 March 2024, read 16 September 2026: the naming of eco, responsible and sustainable as ambiguous in step 2, the accreditation scope requirement in step 7, and the requirement that environmental target claims be supported by a clear and verifiable strategy.
- GOV.UK and the Competition and Markets Authority, "CMA to boost consumer and business confidence as new consumer protection regime comes into force", https://www.gov.uk/government/news/cma-to-boost-consumer-and-business-confidence-as-new-consumer-protection-regime-comes-into-force, published 7 April 2025, read 16 September 2026: the direct enforcement powers and the maximum penalty of 10% of global turnover in step 9.
- GOV.UK, "Single-use plastics ban: plates, bowls, trays, containers, cutlery and balloon sticks", https://www.gov.uk/guidance/single-use-plastics-ban-plates-bowls-trays-containers-cutlery-and-balloon-sticks, published 22 January 2024, last updated 7 October 2024, read 16 September 2026: the items banned with no exemptions, used in step 5 as the worked example of a legal obligation being presented as an environmental choice.

This is a working document prepared for the owner to check against their own certificates and contracts, and for their solicitor or trade body to check any comparative or absolute claim, before anything is published. It is not legal advice and it is not a ruling that the copy complies.

# waste-claims

## You are given
One UK hospitality business's environmental claims, already collected and judged by Claude. Specifically: the business name; every claim quoted exactly as it appears, each carrying the surface it appears on, a photograph or screenshot reference, the date it was captured and the person who captured it; Claude's judgement for each claim of whether it is absolute, comparative or qualified, which of the six principles it was tested against and which it failed, and the rule or ruling that strikes it where it is struck; the rewritten wording for every claim that survives, supplied verbatim and never to be edited; every evidence document offered for a claim, with its title, issuer, date, reference number and what it actually covers; every badge, trust mark, certification and membership on display, with its issuer, authorisation status, expiry date and scope; the list of legal obligations that competing businesses are equally subject to, supplied by Claude with sources, for testing claims that present compliance as a benefit; the enforcement wording and dates; and the quoted source wording Claude relied on, each with its source URL and the date it was read. Where a judgement is missing it arrives as the words `not supplied`.

## Produce
Write into a `./waste-claims-output/` folder:

1. `claims-register.csv` with these columns in this order: `claim_ref`, `claim_text_verbatim`, `surface`, `image_reference`, `captured_date`, `captured_by`, `claim_type`, `principle_failed`, `rule_or_ruling_cited`, `status`, `source_url`, `source_read_date`. `claim_ref` is C001 upward. `surface` is exactly one of `menu`, `specials board`, `window or signage`, `table talker`, `receipt`, `website`, `social media profile`, `social media post`, `delivery app listing`, `vehicle livery`, `email signature`, `other`. `claim_type` is exactly one of `absolute`, `comparative`, `qualified`, `not supplied`. `principle_failed` is empty or exactly one of `truthful and accurate`, `clear and unambiguous`, `omits or hides important information`, `comparison not fair or meaningful`, `does not consider full life cycle`, `not substantiated`. `status` is exactly one of `keep as written`, `keep as rewritten`, `struck`, `not supplied`. Every `struck` row carries a non-empty `rule_or_ruling_cited`.
2. `evidence-register.csv` with columns: `claim_ref`, `document_title`, `issuer`, `document_date`, `reference_number`, `what_it_covers`, `covers_this_claim`, `expiry_date`, `held_on_file`. `covers_this_claim` and `held_on_file` are `yes`, `no` or `not supplied`. A claim with no evidence row appears in `gaps.md` and may not carry `status` `keep as written`.
3. `vague-terms.csv` with columns: `claim_ref`, `term_found`, `appears_alone`, `specific_replacement_supplied`, `replacement_text_verbatim`. `term_found` is exactly one of `eco`, `eco-friendly`, `sustainable`, `sustainably sourced`, `responsible`, `green`, `planet-friendly`, `environmentally friendly`, `natural`, `ethical`. `appears_alone` is `yes` where the claim does not state the specific thing the term stands for in the same sentence.
4. `compliance-presented-as-choice.csv` with columns: `claim_ref`, `claim_text_verbatim`, `obligation_named`, `obligation_source_url`, `competitors_under_same_obligation`, `rule_cited`, `outcome`. One row for every claim that describes the absence of a material or a practice. `competitors_under_same_obligation` is `yes`, `no` or `not supplied`. `outcome` is exactly one of `struck`, `rewritten to remove the implied benefit`, `no obligation applies`, `not supplied`.
5. `badges-and-marks.csv` with columns: `badge_name`, `issuer`, `where_displayed`, `authorisation_held`, `authorisation_reference`, `expiry_date`, `scope_verbatim`, `covers_what_it_is_displayed_beside`, `banned_practice_risk`. `authorisation_held` is `yes`, `no`, `lapsed`, `not supplied`. `banned_practice_risk` is exactly one of `none identified`, `trust mark without authorisation`, `code of conduct signatory claim`, `not supplied`.
6. `rewritten-copy.md` - one block per surviving claim, each giving the claim reference, the original wording verbatim, the rewritten wording verbatim exactly as supplied, the evidence document that supports it with its date, and the surface it will appear on. Nothing in this file is composed, shortened, tidied or improved by Codex.
7. `enforcement-note.md` - a short file stating, in plain sentences, the date the unfair commercial practices provisions apply from, the enforcement bodies, the maximum penalty as supplied, and the fact that an advertising ruling is published under the business's own name. Every statement carries its source. No conclusion about the business's exposure.
8. `gaps.md` - a numbered list of: every claim with `not supplied` in any judgement column; every claim with no evidence row; every evidence document whose `covers_this_claim` is `no` or whose expiry date has passed; every claim carrying a vague term with no specific replacement supplied; every badge with `authorisation_held` of `no`, `lapsed` or `not supplied`; every surface with no capture date or no image reference; any missing source URL or read date; and the review date tied to the next print run.

## Rules
- Codex records, tests and cross-references. It never invents, never composes a claim, never rewrites, shortens, softens or tidies a supplied wording, and never makes the judgement that was supplied to it. This is copy the owner publishes in their own name.
- Every claim is copied exactly as it appears, including its punctuation, capitalisation, spacing and any emoji, into `claim_text_verbatim`. Nothing is normalised.
- Never write `keep as written` against a claim with no evidence row, and never write `keep as rewritten` unless a replacement wording was supplied verbatim.
- Never reinstate a struck claim, and never carry a struck claim into `rewritten-copy.md`.
- Never write a percentage of waste diverted, a carbon figure, a recycling rate, an industry average or a saving into any file unless it was supplied with the document it was read from and that document's date. No such figure exists for a single independent UK venue by default.
- Never state that a claim is compliant, approved, safe to publish or low risk, and never rank claims by severity. None of these goes into any file.
- Never record a rule, a ruling or an enforcement figure without its source URL and the date that source was read, both copied from the input.
- A rule that has not commenced is recorded with its start date and is never applied to copy already published.
- Use British English, GBP for money and DD Month YYYY for every date. No em dashes in any file you write, and any supplied claim containing one is recorded verbatim and flagged in `gaps.md`.
- Every file ends with this line: this is a working document prepared for the owner to check against their own certificates and contracts, and for their solicitor or trade body to check any comparative or absolute claim, before anything is published; it is not legal advice and it is not a ruling that the copy complies.

## Return
The absolute path of each file written, the row count of each CSV, the number of claims collected and the breakdown by surface, the number by status with the rule cited for every struck claim, the number of claims with no evidence document naming each one, the count of vague terms found with the term and the claim reference for each, every claim that presented a legal obligation as an environmental choice with the obligation named, every badge whose authorisation is not held or has lapsed, the claims carried into `rewritten-copy.md` with the evidence date beside each, the enforcement dates and maximum penalty as recorded, the review date, and the `gaps.md` item count.