From September 27, 2026, a new European standard for so called green claims enters into force across EU member states, tightening what businesses can say about the environmental credentials of products and services. Although the United Kingdom is not an EU member, UK companies and advertisers will face materially higher compliance risks because the Competition and Markets Authority has updated its enforcement toolkit and the UK regulatory environment is now more aligned with the new rules.
What changes on September 27
The EU Empowering Consumers for the Green Transition Directive, which requires member states to adopt measures restricting unsubstantiated environmental claims, becomes operative across the EU from September 27. The directive establishes a framework that blacklists certain inherently misleading claims, raises the evidential bar for comparative and absolute green statements, and tightens rules on durability and repairability claims for products.
For businesses that trade across borders, the change matters immediately. Companies that market goods into EU markets will need evidence that meets the directive standards or face removal from shelves, consumer redress obligations and administrative fines under national implementing laws. Even for firms that only operate in the UK, the shift in the regulatory environment increases the likelihood that UK regulators will reference the EU standard when testing the sufficiency of a companys proof.
UK enforcement landscape sharpens
The Competition and Markets Authority has been signalling a tougher posture on greenwashing for several years and has published guidance encouraging firms to make robust, verifiable claims. The UK already has a Green Claims Code, and under the Digital Markets, Competition and Consumers Act 2024 the CMA gained expanded powers to order redress and issue directions. From late 2026 those powers exist alongside a clearer international benchmark, prompting businesses to reassess their marketing, labelling and supply chain documentation.
Legal and compliance advisers in the UK say the combined effect is a practical convergence. When UK courts or the CMA examine environmental statements, they will ask whether the evidence would pass muster under the new EU framework. That raises the stakes for manufacturers, retailers and marketing agencies because weaknesses in lifecycle analysis, benchmark selection or third party certification can now trigger cross border action or consumer class claims.
Which sectors need to act fast
Companies in consumer goods, fashion, electronics, food and building materials are among those most exposed. The directive clarifies rules on claims such as biodegradable, carbon neutral and recyclable, areas where past marketing practice has produced disputes. The fashion sector in the UK has already faced CMA probes, and the new EU standard will be used by commercial rivals and consumer groups as a measuring stick.
Retailers that source from complex supply chains will need to show traceable evidence that supports headline claims. That means contract clauses, supplier attestations and lifecycle studies must be reviewed and often reworked. Smaller brands that rely on generic statements, eco labels or vague sustainability messaging will find compliance more expensive and enforcement riskier.
Business impact and costs
For many companies, compliance will require investment in data systems, third party verification and legal review. In the short term that raises operating costs, but advisers note that the clearer rules may reduce litigation and regulatory uncertainty in the medium term by harmonising what counts as acceptable proof.
Marketing and legal teams will also need to change creative workflows. Claims will have to be accompanied by accessible, verifiable evidence directed at the consumer. Comparative claims require transparent baselines and methodologies, not opaque assertions. The CMA has emphasised that the burden of proof sits with the trader making the claim, and that providers of labels and certificates can be drawn into enforcement if they are not sufficiently rigorous.
Cross border suppliers and retailers must plan now
Businesses that export to the EU should treat the directive as immediately relevant. Translating labelling and advertising into multiple jurisdictions will require more granular evidence packages and possibly different marketing for separate markets. For purely domestic UK-facing operations, the practical effect will depend on how aggressively the CMA uses its new powers, but legal advisers expect a higher rate of investigations and a lower tolerance for ambiguous claims.
Companies should take three immediate steps. First, map all environmental claims in marketing, packaging and online channels. Second, compile or obtain the underlying evidence for each claim, including lifecycle analyses and supplier data. Third, involve legal counsel and compliance teams to test claims against the new EU benchmarks and the CMA guidance to identify weak points and remediation measures.
Why this matters for investors and consumers
Investors increasingly factor environmental misstatements into risk assessments. Firms exposed to greenwashing risk can face regulatory fines, remediation costs and reputational damage. Consumers are more likely to demand refunds, returns or regulatory complaints when claims are discovered to be misleading, creating direct commercial liability.
In short, September 27 is a compliance inflection point. For UK businesses the change is not only about legal alignment with a European directive, it is about a shift in enforcement expectations that brings greater clarity and higher short term costs. Firms that move quickly to tighten evidence and stop making unsupported claims should be better placed to avoid enforcement action and to meet rising consumer expectations.