UK Green Claims Code: What Fashion Brands Need to Know in 2026
Benjamin THOMAS
September 21, 2026
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The tightening of regulations on both sides of the Channel is no reason to stop talking about environmental progress. It favors brands that can demonstrate that progress with data. As regulators align on the same principle, the ability to prove a claim is becoming just as valuable as the claim itself.
Since April 6, 2025, the UK Competition and Markets Authority (CMA) has been able to fine a business up to 10% of its global revenue 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 outlined how to communicate about environmental performance since 2021. What has changed is the cost of getting it wrong.
For fashion brands that sell to UK consumers—including French and European brands—this article explains the Code’s requirements, the key dates to keep in mind, how its six principles apply to your products, and five concrete steps to ensure your claims hold up.
The Green Claims Code is the CMA's guidance on how to make environmental claims without violating UK consumer protection law. It was published on September 20, 2021, following 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 causes less harm to it. This includes not only wording but also symbols, logos, colors, 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. As of 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 that targets UK consumers, regardless of its size or industry. Having headquarters in France or elsewhere in the EU offers no protection: what matters is that the claim reaches UK shoppers, whether through a UK online store, a marketplace listing, or a retail partner.
In five years, the Green Claims Code has evolved from general guidance to a framework backed by direct financial penalties. The fashion industry 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 been in effect since September 27, 2026. Brands selling on both sides of the Channel now face two demanding regulatory frameworks at once.
The Code is based 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 reflect reality and be interpreted the same way by any reasonable shopper. Broad terms such as "eco," "responsible," "sustainable," or "conscious" are the first red flags when nothing explains what they mean. Visual cues matter too: green leaves, earthy packaging, or a proprietary "planet" logo can be just as misleading as words.
When it launched its investigation into the fashion industry, the CMA noted that some products in eco-friendly lines contained as little as 20% recycled fabric. The solution lies in precision: “Shell: 20% recycled polyester” rather than “made with recycled materials.” For furniture, “eco-designed T-shirt” should be replaced with a description of what was actually done—such as a certified wood frame or recycled foam—along with specific figures.
A claim must not omit information that would influence a shopper's decision. It must also reflect the product's entire life cycle: raw materials, manufacturing, transportation, use, and end of life.
A recycled fiber does not make a garment “low-impact” if the rest of its production is carbon-intensive. A “recyclable” sofa offers little benefit if there is no collection or recycling system in place for it. General claims such as “eco-friendly” are the riskiest, because they imply a benefit throughout the entire life cycle.
Comparative claims such as "30% lower carbon footprint" must specify 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 carbon 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 changes have altered the risk profile: liability is now shared throughout the supply chain, good faith no longer provides protection, and UK rules coexist with 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 liable. This includes raw material suppliers, manufacturers, brands, retailers, and online platforms. Simply offering a product for sale can be considered repeating the manufacturer’s claim.
The CMA will typically look first at the business that originated the claim and is best positioned to correct it—which is often the brand. Intermediaries that simply pass on products without adding anything are less liable. Those that embellish a claim are responsible for what they added.
For brands, this works both ways. You are responsible for the data your suppliers provide, and your retail partners will increasingly ask you for evidence to support your claims. Difficulty in obtaining information from upstream sources does not relieve you of the obligation to provide evidence.
A violation does not require any intent to mislead. When determining a fine, the CMA considers the severity of the harm, the degree of culpability, the size of the business, and any mitigating or aggravating factors.
Two factors stand out. Correcting a misleading claim before an investigation begins can reduce the penalty. The absence of an internal process to verify claims is considered an aggravating factor.
A note of perspective: As of early 2026, the CMA had not yet used its new powers to impose fines for greenwashing claims, and its track record consisted of negotiated commitments. [TO BE VERIFIED before publication] The regulator has nonetheless identified greenwashing as an enforcement priority, and the legal tools are now in place.
Since September 27, 2026, Directive (EU) 2024/825 has notably prohibited generic environmental claims that cannot be substantiated by recognized outstanding environmental performance, as well as sustainability labels that are not based on a certification scheme or established by public authorities.
The UK approach is less prescriptive, but it points in the same direction: no claim without evidence. For brands operating 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 of a legal matter than a data-driven process. Each step below transforms a marketing message into a claim you can defend.
List every environmental message found on product pages, labels, swing tags, packaging, campaigns, social media, and marketplace listings. Include product line names, icons, and search filters. Start with your "eco" or "responsible" collections, which pose the highest risk.
For each claim, document the evidence supporting it, how recent that evidence is, and which products it covers. This means measuring impact on a product-by-product and range-by-range basis, not just at the company level. Platforms such as Waro help make this possible at scale, so that each claim can be traced back to its data. [INTERNAL LINK: product impact measurement]
Publish the 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, specify a date, a scope, and the strategy for achieving them. [INTERNAL LINK: low-carbon trajectory]
Include evidence requirements in supplier contracts: certificates, material composition, and production data. Verify this information as appropriate, and review it whenever a supplier, material, or factory changes. Centralizing supplier data collection in a single tool makes these checks much easier to perform and repeat.
Establish a validation workflow involving Marketing, CSR, and Legal before any claim is published. Train everyone who writes or approves claims, including product and e-commerce teams. Review claims regularly, and correct them proactively when the supporting evidence is no longer valid.
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