What Happened: On January 22, 2026, the United Kingdom Competition and Markets Authority (CMA) published new guidance that clarifies how UK consumer protection law applies to environmental (“green”) claims made by businesses at every stage of the supply chain. The guidance supplements the CMA’s existing Green Claims Code and fashion sector guidance, and explains when brands, retailers, manufacturers, and others may each be liable for misleading claims, signaling that businesses throughout the supply chain must ensure green claims are accurate, substantiated, and compliant with UK consumer protection law.
Who is Impacted: Any business that makes, repeats, or relies on environmental claims—including those made by other parties in the supply chain—about products or services offered to UK consumers, including global brands, suppliers, contract manufacturers, private-label and branded retailers, online marketplaces, and certifiers whose marks appear in marketing.
Action Steps: Businesses should identify where environmental claims arise across product lines to understand potential compliance risks. They should also tighten internal processes to verify and document claims. Companies may wish to revisit contracts and information-sharing with suppliers and retailers to clearly allocate responsibilities for substantiating claims across the supply chain. In addition, businesses should monitor environmental claims regulations in the UK, EU, and other international regimes to ensure their practices remain consistent with evolving requirements. Taking these steps can help companies reduce the risk of misleading claims and better prepare for potential CMA scrutiny and requests for evidence.
Deadline: The guidance is non-binding but applies immediately. Following the guidance can help avoid penalties under the Digital Markets, Competition and Consumers Act 2024 (DMCC), which, since April 2025, has given the CMA direct powers to determine consumer law breaches and impose fines of up to £300,000 or up to 10 percent of global annual turnover (whichever is higher) for serious violations.
Background
The CMA is the UK’s primary competition and consumer protection authority. In September 2021, the CMA issued the Green Claims Code, non-binding guidance intended to help businesses comply with consumer protection laws (e.g., the Consumer Protection from Unfair Trading Regulations 2008 and Business Protection from Misleading Marketing Regulations 2008) when making environmental claims.
Although the Green Claims Code already sets expectations consistent with the UK Code of Non-Broadcast Advertising and Direct and Promotional Marketing and the UK Code of Broadcast Advertising, the new supply-chain guidance responds to business requests for clarity on how responsibility for green claims is allocated across increasingly complex, global supply chains. It applies to all participants—from raw material suppliers and manufacturers to brands, distributors, retailers, and online platforms—and should be read alongside the Green Claims Code and any relevant sector-specific guidance.
CMA’s 2026 Supply-Chain Guidance
The latest CMA guidance adopts a broad interpretation of what it means to “make” an environmental claim. A business may be considered to be making a claim based on statements in advertising, on packaging, or online; through imagery, logos, or branding that conveys environmental benefits; or through omissions of material information necessary for consumers to understand the true environmental impact of a product.
Importantly, retailers and marketplaces may incur liability not only for claims they originate, but also for claims they repeat. Merely offering a product for sale can amount to repeating a manufacturer’s green claims. If a claim on packaging or labeling is misleading, both the originating business and the retailer may face exposure under unfair commercial practices rules.
The guidance emphasizes that responsibility is distributed throughout the entire supply chain. Parties that originate claims (e.g., suppliers or manufacturers), frame or highlight them (e.g., brands), or present products for consumers (e.g., retailers and online platforms) may all be accountable. Supply-chain complexity does not remove the obligation to ensure claims are accurate and substantiated.
Breaches of consumer protection law may give rise to criminal or civil enforcement, and notably, in civil proceedings, a lack of intent, an honest mistake, or the exercise of reasonable due diligence will not prevent liability. Best efforts to comply may only be considered when determining the level of penalty, alongside factors such as the seriousness of the breach, the size of the business, and any aggravating circumstances.
Accordingly, the CMA advises businesses to:
- Take reasonable steps to obtain and assess evidence supporting claims.
- Use contractual mechanisms to secure supplier and customer assurances.
- Amend or withdraw claims that cannot be substantiated.
- Reassess relationships with counterparties who cannot provide the necessary support.
- Ensure consumers receive all necessary information to understand the claim and make an informed purchasing decision.
The guidance recognizes that evidence may be dispersed across different entities, but places the onus squarely on any business making or repeating a claim to ensure it is not misleading.
Enforcement Under the DMCC
The DMCC, enacted April 2025, gives the CMA authority to:
- Decide that consumer protection laws (including unfair commercial practices rules) have been infringed.
- Direct changes to business conduct and order redress for affected consumers.
- Impose substantial fines directly – up to £300,000 or up to 10 percent of global annual turnover, whichever is higher, for serious substantive breaches – without going to court.
The CMA’s enforcement approach is guided by its Prioritisation Principles, which frame the core function of the CMA as fostering competition and protecting consumers. In applying those principles, the CMA has indicated it may view conduct as particularly egregious where a business should reasonably have been aware of its consumer law obligations but lacks effective internal controls to verify environmental claims, or fails to follow those controls in practice.
In deciding whether and how to act, the CMA will consider factors such as:
- The strategic significance of intervention and the likelihood of success;
- The likely impact of intervention, including both direct consumer benefits (such as stopping misleading practices or securing redress) and indirect effects (such as deterring similar conduct and promoting a level playing field for compliant businesses); and
- Which entities in the supply chain engaged in the relevant commercial practice and are legally responsible for the claim.
When assessing potentially misleading environmental claims, the CMA may investigate one or more participants in the supply chain—including retailers, brands, manufacturers, and others—and may seek information from multiple entities to determine responsibility and appropriate enforcement action.
Next Steps
The CMA’s supply-chain guidance includes practical suggestions and role-specific checklists for retailers, brands, suppliers, and other participants. Businesses should review the full guidance to assess how those recommendations apply to their particular position in the supply chain. The guidance is available here.
More broadly, the guidance builds on the CMA’s primary objectives of protecting consumers and fostering fair markets. As supply chains become increasingly complex and consumers place greater weight on environmental representations when making purchasing decisions, the CMA has emphasized that businesses must take care to ensure green claims are clear and substantiated. Companies operating in or selling in the UK market should therefore view this guidance as a roadmap for assessing whether their current practices align with UK consumer protection laws.
