UK CMA Publishes Guidance on Making Green Claims Across Supply Chains

Consumer Law Applies to Claims, Presentation and Omissions

The guidance emphasises that “making” an environmental claim is not limited to a single statement on packaging. It can include what a business says on websites and marketing materials, how information is presented (including imagery), and what is left unsaid where missing information could mislead consumers. In practice, this means a claim can become a compliance issue even when it is repeated from another party in the supply chain.

Evidence and Verification Are Central, Even When Data Sits Elsewhere

Supply chains often mean the information needed to substantiate a claim sits upstream, for example with ingredient suppliers, manufacturers or testing providers. The CMA recognises this can make verification challenging, but it still expects businesses communicating claims to consumers to take steps to ensure claims are accurate and not misleading. The guidance points to contractual arrangements and assurances as practical tools to secure evidence, and suggests businesses should rethink how they make claims if verification is not possible.

Enforcement Context: Stronger Direct Powers Under the DMCC Act

The document also outlines the CMA’s enforcement approach, noting that the Digital Markets, Competition and Consumers Act 2024 (in force from April 2025) enables direct consumer enforcement. This can include directions on business conduct, orders for redress, and fines for non-compliance, without necessarily relying on court proceedings.

What This Means for Manufacturers, Brands and Retailers

For manufacturers and suppliers, the guidance increases pressure to maintain up-to-date substantiation and share it with downstream partners. For brands and retailers, it reinforces the need for internal governance: claim approval processes, training, routine checks, and escalation routes when supplier information is incomplete.

Summary

The CMA’s new supply chain guidance signals a shift from treating green claims as a marketing issue to treating them as a managed compliance risk. Businesses that can evidence claims, document assumptions and maintain supplier transparency will be better positioned as enforcement activity accelerates.