UK Green Claims Code: what fashion brands need to know in 2026
Benjamin THOMAS
September 21, 2026
.png){kind=icon}
The tightening of the rules on both sides of the Channel is not a reason to stop talking about environmental progress. It favours brands that can show that progress with data. As regulators converge on the same principle, the ability to prove a claim is becoming as valuable as the claim itself.
Since 6 April 2025, the UK Competition and Markets Authority (CMA) can fine a business up to 10% of its global turnover for a misleading environmental claim, without going to court. In January 2026, it went a step further: new guidance confirmed that brands, retailers, manufacturers and online platforms can all be held liable for the same claim, even when it was made in good faith.
The rules themselves are not new. The CMA's Green Claims Code has set out how to communicate on environmental performance since 2021. What has changed is the cost of getting it wrong.
For fashion brands selling to UK consumers, French and European brands included, this article covers what the Code requires, the key dates to know, how its six principles apply to your products, and five concrete steps to make your claims hold up.
The Green Claims Code is the CMA's guidance on how to make environmental claims without breaching UK consumer protection law. It was published on 20 September 2021, after consultation with businesses and consumer groups.
Its scope is broad. A green claim is any message suggesting that a product, service, brand or business benefits the environment or harms it less. That covers wording, but also symbols, logos, colours, imagery and product names. A "Conscious" collection or a leaf pictogram on a swing tag counts.
The Code does not create new obligations. It explains how existing consumer law applies to environmental claims. Since April 2025, that law is the Digital Markets, Competition and Consumers Act 2024 (DMCCA), which the CMA can now enforce directly.
The Code applies to every business addressing UK consumers, whatever its size or sector. Being headquartered in France or elsewhere in the EU offers no protection: what matters is that the claim reaches UK shoppers, through a UK e-shop, a marketplace listing or a retail partner.
In five years, the Green Claims Code has moved from soft guidance to a framework backed by direct financial penalties. Fashion has been the CMA's test sector from the start.
On the EU side, Directive (EU) 2024/825 on empowering consumers for the green transition has applied since 27 September 2026. Brands selling on both sides of the Channel now face two demanding regimes at once.
The Code rests on six principles. In practice, they boil down to three questions: is the claim true and easy to understand, does it tell the whole story, and can you prove it?
A claim must match reality and be understood the same way by any reasonable shopper. Broad terms such as "eco", "responsible", "sustainable" or "conscious" are the first red flag when nothing explains them. Visual cues count too: green leaves, earthy packaging or an in-house "planet" logo can mislead as much as words.
When it opened its fashion investigation, the CMA noted that some products in eco ranges contained as little as 20% recycled fabric. The fix is precision: "Shell: 20% recycled polyester" rather than "made with recycled materials". For furniture, "eco-designed t-shirt" should give way to what was actually done, such as a certified wood frame or recycled foam, with figures.
A claim must not leave out information that would change a shopper's decision. It must also reflect the product's whole life cycle: raw materials, manufacturing, transport, use and end of life.
A recycled fibre does not make a garment "low impact" if the rest of its production is carbon-intensive. A "recyclable" sofa promises little if no collection or recycling route exists for it. General claims like "eco-friendly" are the riskiest, because they imply a benefit across the entire life cycle.
Comparative claims such as "30% lower carbon footprint" must state the reference point and use a consistent method. Above all, the evidence must exist before the claim is made, and it must be credible and up to date.
This is where product-level data makes the difference. A footprint calculated through a life cycle assessment (LCA), verified supplier data and valid certificates are what turn a marketing message into a defensible claim.
Three shifts change the risk profile: liability is now shared along the supply chain, good faith no longer protects, and UK rules sit alongside an equally demanding EU regime.
The January 2026 guidance is clear: any business that makes, repeats or relies on a green claim can be held responsible. That includes raw material suppliers, manufacturers, brands, retailers and online platforms. Simply offering a product for sale can amount to repeating its manufacturer's claim.
The CMA will usually look first at the business that originated the claim and is best placed to correct it, which is often the brand. Intermediaries that pass products on without adding anything are less exposed. Those that embellish a claim take responsibility for what they added.
For brands, this works both ways. You answer for the data your suppliers give you, and your retail partners will increasingly ask you for the evidence behind your claims. Difficulty in obtaining upstream information does not remove the duty to substantiate.
A breach does not require any intention to mislead. When setting a fine, the CMA weighs the seriousness of the harm, the level of culpability, the size of the business and any mitigating or aggravating factors.
Two factors stand out. Correcting a misleading claim before an investigation opens can reduce the penalty. Having no internal process to verify claims is treated as aggravating.
A note of perspective: at the start of 2026, the CMA had not yet used its new fining powers against green claims, and its track record consisted of negotiated undertakings. [À VÉRIFIER avant publication] The regulator has nonetheless named greenwashing as an enforcement priority, and the legal tools are now in place.
Since 27 September 2026, Directive (EU) 2024/825 has notably banned generic environmental claims that cannot be backed by recognised excellent environmental performance, as well as sustainability labels not based on a certification scheme or set by public authorities.
The UK approach is less prescriptive, but it points the same way: no claim without evidence. For brands active in both markets, the pragmatic option is to build a single evidence base that meets the stricter of the two standards.
Compliance with the Code is less a legal exercise than a data exercise. Each step below turns a marketing message into a claim you can defend.
List every environmental message across product pages, labels, swing tags, packaging, campaigns, social media and marketplace listings. Include range names, icons and search filters. Start with your "eco" or "responsible" collections, which carry the highest risk.
For each claim, document what proves it, how recent the proof is and which products it covers. This means measuring impact product by product and range by range, not only at company level. Platforms such as Waro help make this possible at scale, so each claim can be traced back to its data. [LIEN INTERNE : mesure d'impact produit]
Publish minimum criteria for any eco collection and include only products that meet all of them. For comparative claims, define the reference point and the method in advance. For environmental targets, give a date, a scope and the strategy to reach them. [LIEN INTERNE : trajectoire bas-carbone]
Build evidence requirements into supplier contracts: certificates, material composition, production data. Check this information proportionately, and check it again whenever a supplier, a material or a factory changes. Centralising supplier data collection in one tool makes these checks far easier to run and to repeat.
Set up a validation workflow between Marketing, CSR and Legal before any claim goes live. Train everyone who writes or approves claims, including product and e-commerce teams. Review claims regularly, and correct them proactively when the evidence no longer holds.
.png)
.png)
.png)
