EU & UK Greenwashing Rules: What Retailers Need to Know in 2026

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. In the EU, new anti-greenwashing rules under Directive (EU) 2024/825 came into force on 27 September 2026. 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 across the EU and UK, look at the timelines, and uncover what practical readiness should look like for retailers.

Key Dates

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 EU greenwashing regulations designed to protect consumers from misleading environmental claims and commercial practices.

What It Does

The Directive prohibits:

• Generic environmental claims such as “eco” or “green” where recognised excellent environmental performance relevant to the claim cannot be demonstrated.
• Sustainability labels not based on approved certification schemes or established by a public authority
• Environmental claims about an entire product or business where the claim actually relates to only one aspect of the product or a specific activity
• Claims that a product has a neutral, reduced or positive greenhouse gas impact where these are based on carbon offsetting 
• Claims about future environmental performance without clear, measurable commitments, supported by a detailed implementation plan with measurable, time-bound targets and independent verification.

The new rules came into force on 27th 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.

EU Green Claims Directive: What’s Its Status in 2026 ?

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.

UK Anti-Greenwashing Rules: Enforcement Is Already Active

In the UK, environmental claims are subject to consumer protection law under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act). Its unfair commercial practices provisions came into force on 6 April 2025, replacing and updating the previous Consumer Protection from Unfair Trading Regulations 2008. These rules are enforced by the Competition and Markets Authority (CMA) and other consumer protection enforcement bodies, including Trading Standards. 

The CMA’s Green Claims Code sets out practical guidance.

What This Means

For retailers, the UK greenwashing regulations and CMA guidance mean environmental claims need to be backed by robust evidence

Claims must be:

• Truthful and accurate
• Clear and unambiguous
• Substantiated with credible, up-to-date evidence and fair and meaningful comparisons
• Considerate of the full life cycle where relevant 
• Not misleading by hiding or omission of evidence.

The CMA can impose penalties of up to 10% of worldwide turnover for breaches of consumer protection law.

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 embedded across the wider regulatory landscape. It does not exist in isolation, but 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 Retailers Should Be Doing Now

With the new EU rules now in force, retailers should ensure environmental claims can be supported by clear, accessible evidence. In practice, this means:

1. Supplier-Level Evidence: Formal Tier 1 declarations and documented sourcing routes.
2. Certification Governance: Centralised storage, validation and expiry monitoring of recognised schemes.
3. Product-to-Claim Mapping: Clear linkage between product attributes and marketing language.
4. 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

As the EU rules take effect the focus is increasingly on whether environmental claims can be substantiated with clear, reliable evidence and not simply whether they reflect good intentions. 

Final Thought

The EU Anti-Greenwashing Directive 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.