With evolving EU regulations and national consumer authorities strengthening enforcement, retailers can no longer afford vague sustainability claims. Two key pieces of legislation are shaping this landscape:

The Empowering Consumers for the Green Transition Directive (EU 2024/825) is already adopted and entered into force on March 26, 2024. Member States must transpose it into national law by March 27, 2026, with enforcement beginning September 27, 2026. From that date, every generic environmental claim will need substantiation — "sustainable," "eco-friendly," or "green" will only be allowed with proof. Member states are already preparing implementation legislation, with countries like Denmark proposing bills in early 2025 to transpose the directive into national law.

The Green Claims Directive, originally proposed to complement the Empowering Consumers Directive with detailed substantiation requirements, was paused by the European Commission in June 2025 due to concerns over regulatory burden on micro-enterprises. While not formally withdrawn, its future remains uncertain.

Regardless of regulatory developments, the compliance challenge is immediate, not distant. In the complexity of large product assortments, achieving compliance often feels overwhelming. Regulators and industry are working together to ensure consumer trust, but the practical implementation challenges are substantial — particularly for retailers who must verify and substantiate claims across thousands of products from diverse suppliers.

The Scale Problem: Thousands of Products, Thousands of Claims

Retailers with 10,000+ products face a unique challenge that extends far beyond what individual brands experience:

Volume: Even if only 10% of products carry a green claim (certified organic cotton, recycled polyester, branded materials), that still means 1,000 claims to monitor, update, and substantiate — all originating from different brands with varying documentation standards.

Variation: Each brand and supplier uses its own language and certification references. Harmonising this across an e-commerce site while ensuring compliance becomes a constant battle involving multiple internal stakeholders.

Velocity: Fashion retailers depend on immediate product onboarding — when inventory arrives, it must be online instantly to maximize sales windows and minimize stock-holding costs. This speed leaves little room for compliance verification before products go live.

Cross-departmental complexity: Current compliance approaches require time-consuming collaboration between legal, ESG, and ecommerce teams for every product review. This internal workflow bottleneck makes systematic compliance nearly impossible at scale.

The result? Until recently, retailers had no systematic way to verify supplier claims or product information. Most rely on manual sample reviews — sporadic checking of individual products rather than comprehensive oversight. But enforcement deadlines are changing the stakes: compliance is no longer optional. With no existing systems for large-scale green claim verification and the impossibility of manually checking thousands of products, retailers find themselves caught between regulatory expectations and operational reality.

The Enforcement Reality

From September 2026, every vague claim becomes a liability. The risks are tangible and imminent, with retailers bearing the full legal responsibility regardless of claim origin. Under the Empowering Consumers Directive, which becomes enforceable in September 2026, claims like "sustainable," "eco-friendly," or "green" are explicitly banned unless backed by precise, verifiable evidence. Even claims based on legitimate certifications (like GOTS or FSC) can become problematic if:

  • The certification is expired or not traceable to the exact product
  • The claim is communicated in a way that exaggerates its scope (e.g. "sustainable dress" when only 30% of the fabric is certified)
  • Documentation isn't readily available when consumer authorities request proof
  • The original supplier documentation doesn't meet regulatory substantiation requirements

For a retailer managing thousands of products from multiple suppliers, maintaining oversight without systematic support is close to impossible. The challenge is compounded by the fact that retailers must trust and verify supplier claims while being held to the same compliance standards as the original claim creators.

The Consumer Trust Gap

Beyond regulation, there's a deeper consumer trust crisis that affects retailers even more acutely than brands. Years of unsubstantiated sustainability claims have eroded faith in fashion retailers, who are often seen as the final gatekeepers of product information. The European Commission's own research shows that 53% of green claims give vague, misleading or unfounded information, while consumer trust in environmental claims is "extremely low." A recent EU screening of the textile sector found that 39% of sustainability claims could be false or deceptive.

This skepticism reflects years of inconsistent sustainability communication across the industry. When claims don't align with reality, it's not just fines at stake but long-term brand viability. For retailers, this trust deficit is particularly challenging because consumers hold them accountable for all product claims, regardless of whether the retailer or the brand created them. Trust drives loyalty in a highly competitive market where consumers have endless alternatives and growing environmental awareness.

The Path Forward: Turning Complexity Into Clarity

When analysing data from leading EU fashion retailers, we've observed that manual sample reviews and existing internal workflows simply don't address this new compliance requirement. Generic AI tools, while increasingly popular, fall short of addressing this specialized compliance need. These models struggle with the specificity required for green claims verification — they're trained on broad datasets with knowledge cut-off dates, produce inconsistent results, and lack integration with authoritative certification databases that regulatory compliance demands.

For retailers preparing for the new regulatory landscape, compliance readiness requires a systematic approach:

  • Implement automated product scanning across your entire catalog using specialized compliance criteria (look for solutions that check multiple compliance checkpoints) rather than relying on sporadic manual reviews

  • Establish verification processes that can check certifications and product data against authoritative sources in real-time, removing the burden of manual validation from your teams

  • Standardize sustainability language across all brands and categories in your assortment to ensure consistent compliance regardless of which supplier provided the original claim

  • Build proactive documentation systems so you're prepared with proper evidence when regulators, partners, or consumers request proof of your claims

  • Streamline cross-departmental workflows by creating a single source of truth that legal, ESG, and ecommerce teams can all reference for compliance decisions

Each of these steps helps shift compliance from bottleneck to growth driver. A systematic approach to green claims verification positions retailers proactively for regulatory scrutiny rather than leaving them scrambling to respond after enforcement begins.

Retailers who adopt systematic compliance approaches can transform regulatory requirements from operational burden into competitive advantage. Instead of reactive compliance, they can proactively showcase verified sustainability initiatives — at scale — while building the consumer trust that drives long-term success.

The Bigger Picture

The fashion industry's evolution toward transparency isn't just about avoiding regulatory issues — it's about rebuilding consumer trust and creating a marketplace where authentic sustainability efforts are properly recognised. Large retailers, with their significant market influence and thousands of products from diverse suppliers, play a crucial role in this transformation.

When major retailers adopt systematic compliance and communicate sustainability claims clearly and credibly, they don't just protect themselves — they help pioneer industry standards and rebuild consumer confidence. Their scale gives them unique power to demand better documentation from suppliers, set transparency benchmarks, and demonstrate that verified environmental communication is both possible and profitable.

Most importantly, retailers who master transparent sustainability communication position themselves as trusted intermediaries between consumers and products, empowering consumers to make choices that match their values. In a market where trust has been eroded, this becomes a powerful competitive advantage.

At BetterChoice, we've built our platform specifically for this challenge: helping retailers transform 10,000+ product portfolios from compliance complexity into verified, trustworthy product communication — without the operational burden of manual reviews or complex cross-departmental workflows.

The retailers who act now won't just meet the 2026 deadline — they'll set the new industry standard.

Ready to explore how systematic compliance can become your competitive advantage? Let's discuss your specific challenges.