Greenwashing complaint against home heating trial that risks misleading consumers 

Opportunity Green has filed a complaint to the Competition and Markets Authority (CMA) against Scotland Gas Networks plc (SGN) for alleged greenwashing in relation to its hydrogen home heating trial in Fife, Scotland. The complaint argues that SGN’s portrayal of the trial risks misleading consumers as to the merits, and environmental credentials, of hydrogen home heating.   

Background 

Opportunity Green has filed a complaint with the UK’s Competition and Markets Authority (CMA) against Scotland Gas Networks plc (SGN) concerning its hydrogen heating trial in Fife, Scotland. The complaint alleges that SGN has made misleading environmental claims about hydrogen heating in its websites and promotional materials directed at local residents and prospective trial participants. Those claims present hydrogen as “clean burning”, “zero-carbon”, and capable of providing “green energy” to millions of homes.

The complaint argues that these claims omit critical information and conflate different types of hydrogen with very different environmental impacts. This risks misleading consumers about the emissions, efficiency, and feasibility of hydrogen as a solution for home heating.

This is particularly important given that the UK Government has yet to make its final decision on the role of hydrogen in home heating, expected in 2026. Misleading green claims risk shaping consumer choices and policy decisions based on inaccurate information. If the gas grid were repurposed for hydrogen, up to 85% of UK households could be affected, making truthful, evidence-based information essential to protecting consumers and the public interest. 

What’s in the complaint?  

The key elements of Opportunity Green’s complaint are:

• Misleading green claims: SGN’s promotional materials present hydrogen as “clean”, “zero-carbon” and uniquely capable of decarbonising home heating, while omitting critical information and making claims that are ambiguous or unsubstantiated.

• Conflation of hydrogen types: Claims rely on the environmental benefits of green hydrogen while drawing on the cost and scalability profile of blue hydrogen, produced from fossil gas. This creates a misleading picture of hydrogen heating’s environmental impact and feasibility.

• Emissions and safety concerns: Evidence on nitrogen oxide (NOx) emissions from hydrogen combustion is not presented accurately.

• Hydrogen is not suitable for home heating: Independent evidence, including from the UK Climate Change Committee, shows that hydrogen is not a viable or cost-effective option for decarbonising residential heating and that relying on it would delay emissions reductions. Electric heating, particularly heat pumps, is more efficient, scalable, and sustainable, yet SGN’s materials do not provide a fair or meaningful comparison to consumers.

• Consumer harm: The claims may influence decisions consumers would not otherwise make, including joining the Fife trial or retaining gas boilers instead of switching to clean, efficient electric heating.  

Our recommendations  

The complaint requests that the CMA:

• Investigate SGN’s promotional materials and communications for potential breaches of the Code.

• Require SGN to amend its materials to ensure compliance with the Code (and notify consumers of such amendments by the same medium used for the relevant claims, including dissemination of corrections in paper copies to consumers), including:

  • Providing clear and accurate information about NOx emissions from hydrogen combustion.

  • Substantiating claims about the environmental benefits, scalability, and cost-effectiveness of hydrogen heating with robust evidence.

  • Clearly distinguishing between green hydrogen and other forms of hydrogen in all claims.

• Take appropriate enforcement action to prevent further dissemination of misleading claims by SGN.

• Issue industry-wide guidance on this issue, with particular regard to any other actual or potential hydrogen heating trials.