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Getting it right: What the CMA’s new supply chain guidance means for your green claims
The Competition and Markets Authority (CMA) has published new guidance to support its Green Claims Code. This guidance answers a question that has been bubbling under the surface for years:
If a green claim passes through multiple hands before reaching the consumer, who is responsible for it?
The answer is simple: if you make, present or repeat a green claim, you are accountable for it.
The new guidance explains how responsibility works in practice and sets out checklist-style expectations for retailers, brands, manufacturers and suppliers to help ensure claims are clear, accurate and not misleading.
Jump to the checklist most relevant to you:
Why this guidance has been introduced
Supply chains are rarely linear or simple. A single environmental claim may originate with a raw material supplier, be adopted by a manufacturer, incorporated into brand messaging, and then repeated by multiple retailers.
The CMA has recognised this complexity. Businesses have been asking:
- If we’re repeating a green claim a supplier tells us, are we responsible?
- What if the evidence sits elsewhere in the chain?
- What if we don’t have full visibility of sourcing?
Consumer protection law applies to commercial practices that influence consumer decisions. That includes advertising, labelling, product descriptions and omissions of important qualifying information.
Complexity does not remove responsibility. This new guidance provides that clarity – and it does so within the framework of the Digital Markets, Competition and Consumers Act 2024 (DMCC Act), which now gives the CMA direct enforcement powers, including the ability to impose fines and order redress.
What counts as making a green claim
In line with the Green Claims Code, the new guidance reinforces that making a claim is broader than many businesses assume.
It isn’t limited to writing marketing copy. Claims can include:
- Statements on packaging or product labels
- Product descriptions (including those uploaded automatically from a supplier feed)
- Marketing materials and imagery
- Grouping products into an “eco” or “sustainable” range
- Failing to mention limitations or important contextual information
For example, describing a product as “compostable” without clearly stating that it requires specialist processing, not home composting, is likely to mislead. Key qualifying information must sit close to the claim. It should not be hidden behind QR codes or buried in small print.
This is where many businesses unintentionally step into risk: not through deliberate exaggeration, but through incomplete communication.
For simple, practical guidance on the Green Claims Code, our Anti-Greenwash Playbook and bite-sized video series let you explore the topics at your own pace.
What the CMA expects in practice
Under the Digital Markets, Competition and Consumers Act 2024, the CMA now has direct enforcement powers. It can determine breaches of consumer law, order redress and impose fines without going to court.
The CMA has made clear it will prioritise the most harmful and egregious practices. Businesses are at greater risk where they ignore established guidance, repeat claims that have already been challenged, or lack effective internal processes for verifying environmental claims.
In practical terms, this is about governance. The CMA will look at whether you have appropriate systems for substantiating claims, reviewing them regularly and correcting them quickly if they become inaccurate.
Proactive compliance will not eliminate risk, but the absence of it will significantly increase it. Environmental claims are no longer just a marketing issue. They require coordinated oversight across procurement, legal, compliance and sustainability functions.
What this means for businesses across the supply chain
The practical impact of this guidance differs depending on where you sit in the chain. But, the underlying principle is shared accountability.
Below are structured checklists reflecting the CMA’s expectation for your business.
Green claims checklist for suppliers and manufacturers
- Maintain robust records
Evidence relating to raw materials, provenance, testing and certifications must be accurate, current and well documented.
- Enable downstream verification
Retailers and brands depend on upstream transparency. When information is commercially sensitive, alternative forms of independent verification may be appropriate.
- Mind your language
Absolute terms used casually (such as “eco-friendly”) can easily travel down the chain and become consumer-facing claims. If language cannot be substantiated, it should not be used.
- Communicate changes proactively
If shortages, substitutions or sourcing adjustments affect environmental credentials, have a process in place to communicate this, so claims can be promptly reviewed.
Green claims checklist for retailers
- Verify before you communicate
Have processes in place to obtain robust, credible and up to date evidence before advertising products or services with environmental claims. This could involve requesting certificated, substantiating documents, or formal declarations from suppliers.
- Build assurance into supplier relationships
Contracts and onboarding processes should include requirements for accurate environmental information, with clear obligations to notify retailers of material changes.
- Conduct ongoing reviews
Claims should not be verified once and forgotten. Regular sampling of product descriptions, documentation checks and periodic supplier confirmations can help ensure continued accuracy.
- Monitor supply changes
If sourcing, composition or manufacturing processes change, claims may no longer be valid. Retailers need mechanisms to detect and respond to changes quickly.
- Be careful with “Eco” ranges
Grouping products into one sustainable range creates an implied claim. Ensure each individual product genuinely meets the stated criteria.
Green claims checklist for brands selling through third-party retailers
- Substantiate every claim
Brands must hold credible, up to date evidence for every green claim the originate. This could be about composition, sourcing, recyclability or emissions impact.
- Provide retailers with assurance
Retail partners should be given security that claims are accurate. This may include sharing certificates, summaries of substantiation, or formal declarations where full disclosures are not possible.
- Update claims promptly
If supply chains change or evidence becomes outdated, product descriptions and marketing materials must be amended without delay, and retailers informed.
- Avoid overclaiming
Precision matters. If only one component of a product is recycled, the claim must reflect that clearly. Broad, absolute claims such as “100% sustainable” are particularly high risk.
For the official CMA guidance, see Making green claims: Getting it right, across the supply chain.
If you have questions or want a sense check on website copy, ads or customer communications, we’re happy to help. You can also explore our greenwashing advice and training or our Anti-Greenwash Playbook for practical tips.
