UK CMA tightens supply‑chain green claims rules for fashion brands, escalating enforcement

The UK Competition and Markets Authority has moved green claims out of marketing and into enforceable law with its guidance Making green claims: Getting it right, across the supply chain, published on 22 January 2026, and backed by the Digital Markets, Competition and Consumers Act 2024, in force from April 2025. That pairing gives the CMA powers to issue directions, orders for redress and fines without necessarily going to court, and exposes firms to administrative penalties of up to 10% of global turnover or £300,000, with additional daily penalties while breaches persist.

The explainer clarifies responsibility along complex supply chains and makes a blunt legal point: any company that repeats, relies on or disseminates green claims may face enforcement action. White & Case expanded on the guidance in an alert published on 19 February 2026, warning that downstream businesses must be able to access sufficient upstream information to verify claims and take reasonable steps to do so, or else change, qualify or reconsider the claim or reassess the trading relationship.

The legal mechanics are starkly practical. Fieldfisher explains that the DMCCA “grants the CMA direct enforcement powers to decide whether consumer protection laws have been breached and impose penalties without requiring court proceedings,” and notes that penalties “can reach up to 10% of global annual turnover or £300,000 (whichever is greater), with additional daily penalties for non-compliance.” Useforesight summarises the regulatory shift as turning green claims “from a marketing issue to a managed compliance risk,” reflecting how sanctions are now directly reachable.

Retailers and customer-facing brands sit in the enforcement spotlight. The guidance signals the CMA will likely press the party best placed to remedy an issue, which places downstream brands squarely at risk even when evidence sits with manufacturers or ingredient suppliers. Petersandpeters authors Maria Cronin and Cara Haslam emphasise that the Supply Chain Guidance builds on the existing Green Claims Code and that the CMA will prioritise cases of “strategic significance,” where enforcement can change sector practice.

Practical mitigation measures are detailed across the commentary: contractual assurances, up-to-date substantiation, documented assumptions and internal governance such as claim-approval processes, training, routine checks and escalation routes. White & Case’s LinkedIn promotion of their analysis, shared by Dr. Michael Engel and listing co-authors Euan Burrows, Marc Israel, Clare Connellan, Stephen Shergold, Peter Citron and Georgia Callaghan, delivers the counsel in plain language: “Verify, don’t assume – retailers and brands can’t rely blindly on supplier assurances; reasonable steps to verify environmental claims are expected.” Their post adds, “Enforcement risk is real – failures to verify claims expose businesses to potential fines of up to 10% of global turnover under the new Digital Markets, Competition and Consumers Act,” and states, “Liability flows through the supply chain – The CMA will prioritise cases involving systemic governance and compliance failures. In practice, downstream businesses, particularly retailers and customer-facing brands, are likely to be the primary enforcement targets.” The post closes with, “Act now – robust processes, governance and documentation reduce both reputational and financial exposure.” Dr. Michael Engel’s LinkedIn snippet shows 5,237 followers as displayed in the post promotion.

Consumer pressure underpins the regulator’s urgency. Petersandpeters cites a BearingPoint survey finding that 62% of UK consumers take sustainability criteria into account when buying, strengthening the CMA’s stated interest in actions that deliver both direct and indirect sector-wide impact.

For fashion brands and retailers the message is concrete and immediate: the CMA’s 22 January 2026 Supply Chain Guidance plus the DMCCA’s direct enforcement powers mean board-level governance, supplier contracts and verifiable substantiation are no longer optional safeguards but legal necessities. Failure to act risks material fines, daily penalties and regulatory orders that can change trading practices across an entire supply chain.