Sustainability claims are no longer just a brand positioning tool, they are becoming a regulatory risk area.
Across both the European Union and the United Kingdom, enforcement around environmental marketing claims is intensifying. For fashion and retail businesses operating complex global supply chains, the shift is significant:
The question is no longer “Can we say this?”
It is now “Can we defend this?”
Below, we clarify the current legal landscape accross the EU and UK, look at the timelines, and uncover what practical readiness should look like for retailers.
Read on to discover:
The EU Position: Anti-Greenwashing rules are coming into force
The UK Position: Enforcement is already active
Where retail risk typically sits
The broader regulatory intersection
Key Dates
🇪🇺 EU Anti-Greenwashing Directive transposition deadline: 31 March 2026🇪🇺 Expected enforcement start: 27 September 2026
🇬🇧 UK green claims enforcement: Already active
🇬🇧 Stronger CMA enforcement powers (DMCC Act): Now in force
Retailers operating across both markets must treat green claims as a cross-border compliance issue.
The EU Position: Anti-Greenwashing REFORM ADOPTION
Directive (EU) 2024/825
Empowering Consumers for the Green Transition - This directive amends the Unfair Commercial Practices Directive (UCPD) and introduces specific rules targeting greenwashing.
What It Does
The Directive prohibits:
- Generic environmental claims such as “eco”, “green” or “sustainable” unless supported by recognised evidence
- Sustainability labels not based on approved certification schemes
- Claims about future environmental performance without clear, measurable commitments
- Omitting material information about environmental characteristics
Member States must transpose the Directive by 31 March 2026, with application expected from September 2026. This is not new law, it is strengthened enforcement of consumer protection principles, now specifically focused on greenwashing.
For retailers selling into EU markets, this creates a clear compliance deadline.
What about the Green Claims Directive?
There has been confusion around the separate Green Claims Directive proposal. Originally Proposed in March 2023, it would have introduced:
- Detailed scientific substantiation methodologies
- Potential third-party verification requirements
- Harmonised EU-wide assessment standards
However, negotiations stalled in 2025 and it has not been adopted into law. For retailers, the practical position is simple: Prepare for enforcement under existing consumer protection reforms, not speculative future requirements.
Key point: As ESPR and Digital Product Passports introduce structured product-level environmental data, the connection between product information and marketing claims will become even more direct.
The UK Position: Enforcement Is Already Active
In the UK, environmental claims are governed by: Consumer Protection from Unfair Trading Regulations 2008, enforced by the Competition and Markets Authority (CMA) and Trading Standards.
The CMA’s Green Claims Code sets out practical guidance.
What This Means
Claims must be:
- Truthful and accurate
- Clear and unambiguous
- Substantiated with credible evidence
- Not misleading by omission
There is no future implementation date in the UK. Enforcement is happening now.
Where Retail Risk Typically Sits
For most fashion brands and retailers, exposure does not sit in policy documents.
It sits in:
- Product descriptions
- Online marketing claims
- Hangtags and packaging
- Corporate sustainability statements
Consider a simple example: A product marketed as “sustainably sourced cotton” must be supported by:
- Valid supplier certification
- Clear product-to-supplier mapping
- Current certificate status
- Recognition of the certification scheme
- Evidence that the claim reflects the product and is not just a supplier policy
If any link in that chain is weak, the claim becomes vulnerable. This is where greenwashing enforcement intersects directly with supply chain governance.
The Broader Regulatory Intersection
Green claims risk is now structurally embedded across the regulatory landscape, however it does not reside in isloation, it intersects with:
- ESPR and Digital Product Passports, which formalise product-level environmental data
- Packaging and EPR rules, where material claims must align with reported data
- Corporate sustainability reporting (CSRD), where public disclosures increase scrutiny
- Due diligence frameworks (CSDDD), where sourcing claims must reflect operational reality
- CSRD/CSDDD “Omnibus” changes, which adjust scope and timing but do not remove claim substantiation expectations
In short: marketing, sourcing, compliance and reporting are no longer separate conversations.
What 2026 Readiness Looks Like
Retailers should be moving towards structured defensibility. In practive, this means:
- Supplier-Level Evidence: Formal Tier 1 declarations and documented sourcing routes.
- Certification Governance: Centralised storage, validation and expiry monitoring of recognised schemes.
- Product-to-Claim Mapping: Clear linkage between product attributes and marketing language.
- Audit Trail Infrastructure: Ability to respond to regulator enquiries with timestamped, retrievable documentation.
How Segura Supports Retailers: From Data Capture to Defensibility
Through Segura, most clients are already:
- Capturing supplier information
- Tracking certifications
- Expanding traceability
- Managing audits and CAPs
The question is not whether data exists. It is whether that data is:
- Structured
- Validated
- Linked to products
- Accessible to Legal and Compliance
- Exportable in regulator-ready format
Segura supports retailers in operationalising this “evidence layer” through:
- Structured supplier declaration workflows
- Certification capture and expiry tracking
- Tier mapping and traceability oversight
- Centralised reporting and audit trails
As ESPR and Digital Product Passports formalise product-level data, the connection between product information and marketing claims will only become more direct.
Retailers who treat supplier data governance as compliance infrastructure, not just ESG reporting, will be significantly better positioned with structured, accessible evidence.
The Executive Reality
Green claims risk is no longer limited to marketing teams, it is a governance issue touching:
- Legal
- Sustainability
- Sourcing
- Finance
- Board oversight
During 2026, regulators will likely move on from asking whether a claim reflects good intention, they will ask whether it is supported by structured evidence.
Final Thought
2026 will not introduce greenwashing enforcement, it will formalise it.
Retailers who invest now in supplier data governance, certification oversight and claim-to-evidence alignment will reduce regulatory exposure and strengthen credibility in an increasingly scrutinised market.
If you would like to assess your current readiness, the Segura team can support a focused compliance review aligned to your existing supplier workflows. Get in touch with us today: info@segura.co.uk.

