Key takeaway
What This Development Means
The UK CMA has clarified how consumer law applies to environmental claims when products pass through multiple suppliers, manufacturers and retailers. The guidance strengthens expectations on evidence, transparency and internal controls to reduce greenwashing and legal exposure.
Who can be liable for misleading green claims in the UK supply chain?
The CMA guidance explains that liability can sit with multiple parties, including suppliers, manufacturers, brands and retailers, depending on who made or repeated the claim and what information was presented or omitted. Businesses cannot rely on the fact that a claim originated elsewhere if they communicate it to consumers.
What practical controls help reduce green-claims risk?
Businesses should implement evidence collection and review processes, build contractual obligations for substantiation and updates, and train teams on what counts as an environmental claim. Regular spot checks of product copy and supplier documentation, plus clear escalation when evidence is missing, are central to defensible compliance.
Source basis: Competition and Markets Authority (GOV.UK), “Making green claims: Getting it right, across the supply chain” (22 January 2026)
The UK Competition and Markets Authority (CMA) has published new guidance on “making green claims” across complex supply chains, responding to stakeholder requests for clarity on who is responsible for environmental claims and what evidence is needed to support them. The document supplements the CMA’s Green Claims Code and is intended for businesses at every stage of the product journey, from suppliers and manufacturers to brands and retailers.
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.
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