Traditional approaches - spot-checking and relying on supplier-provided data or certification schemes - worked when expectations were lower. But evolving regulations mean even compliant-looking claims may no longer meet legal standards. In 2026, anti-greenwashing legislation will require businesses to ensure that all green claims are accurate, shifting accountability to retailers. The United Kingdom's Competition and Markets Authority (CMA) latest green claims guidelines stress supply chain accountability and evaluation of internal processes to ensure green claims comply with consumer law.
The Claims Monitoring Challenge Fashion Retail Face
Consider the operational reality of a mid-sized fashion e-commerce platform. You manage over 5,000 active products at any given time. Each product features green claims scattered across multiple locations, including "made with organic cotton" in the title, "carbon neutral shipping" at checkout, recycled packaging claims in descriptions, certification badges in image galleries, and material percentages in specifications.
That's potentially over 30,000 claims to check and verify. These details and texts are not static. Marketing updates product descriptions. Certifications have rules for logo use, and new certifications appear as suppliers earn them. Material information changes with sourcing.
Fashion retailers are responsible for every green claim on thousands of changing products. Manual methods like random sampling and spot-checking are inadequate at today's scale. Even the use of AI to write or enrich product descriptions comes with uncertainty, as many go online before human review, risking unclear claims or omitting information needed to avoid greenwashing.
No compliance team can realistically verify all these claims manually. Checking 50 products daily would take 100 days to review your catalogue once, during which many products change and hundreds more are added — far exceeding most compliance budgets.
Retailers adopted spot-checking and internal guidelines, but these were only temporary answers to an unmanageable scale problem. With 2026 regulations now in effect, relying on manual workarounds is no longer sustainable. Retailers need tools and systems capable of continuous, comprehensive monitoring to meet regulatory expectations.
Unverified claims — such as unsubstantiated 'organic cotton' references, broad 'eco-friendly' messaging, or recycling claims without full context — represent compliance gaps that warrant attention. Demonstrating robust internal processes will be key if regulators review your approach.
How New UK Enforcement Powers Chances Fashion's Compliance Calculus
In their 2026 guidance, backed by enforcement powers from the DMCC Act 2024 (effective April 2025), the Competition and Markets Authority not only updated the rules but also clarified them with examples. They fundamentally altered the risk calculation that made previous workarounds tolerable.
The regulatory changes significantly increase business risk through three key shifts:
- Shared liability for green claims.
- Faster enforcement mechanisms.
- A focus on internal monitoring processes during investigations
We explain how each of these — shared liability, faster enforcement, and a focus on internal processes — increases legal and financial exposure for retailers. These risks include fines, legal action, and reputational damage when green claims are non-compliant or at risk of greenwashing across the products listed on your platform.
Shared liability: All businesses in the supply chain can now share full responsibility for green claims. Retailers, brands, and manufacturers are equally liable, even if claims originate from suppliers.
This means that approaches which used to be sufficient are no longer valid. CMA guidance states there's no defence for unwitting breaches. Relying on supplier information alone is insufficient — if a green claim appears on your platform, your business is liable.
Faster enforcement: UK consumer authorities can now enforce rules more quickly. The CMA can directly decide on infringements, issue directions, order redress, and fine businesses without going to court. What once took years will likely now happen in months.
Internal processes focus: The CMA guidance explicitly states that when determining the severity of violations and calculating fines, they will examine what internal processes you, as the retailer, had in place.
What verification systems did you use? How did you monitor claims across your catalogue? Was sufficient information collected to substantiate the green claim? What contractual assurances did you require from suppliers?
The CMA guidance stresses that strong internal verification — comprehensive, consistent, and proactive — is now essential. Retailers who prioritise robust internal systems will be better positioned to meet regulatory expectations and demonstrate compliance with confidence.
The Global Ripple Effect
This rise in regulatory expectations isn't limited to the UK. ICPEN's 2025 statement noted that anti-greenwashing laws are similar and enforced across borders, with fashion prioritised. As UK regulators stress the importance of strong internal processes, others will follow.
Green claims expectations and anti-greenwashing measures are consistent across Europe, with authorities adopting each other's practices. Denmark, Sweden, France, and the Netherlands have their own green claims guidelines. Each calls for substantiation, specificity, and transparent information. Success in the UK will become the enforcement template for Europe.
Consequently, fashion retailers must implement monitoring systems that operate seamlessly across all markets — not just country-specific fixes. This ensures a defensible standard that satisfies UK regulators, matches EU expectations, and complies with a globally coordinated approach among consumer authorities.
The New Reality
The regulatory landscape for green claims is undergoing a fundamental shift. The question for retailers is whether current compliance approaches can meet these new requirements and manage the legal risk that comes with them. Given recent enforcement changes, solutions that once offered adequate protection may no longer provide a reliable defence against greenwashing investigations.
The core challenge is now unavoidable: retailers are liable for every green claim on their platforms, regardless of who made it. With enforcement becoming faster and more severe, only systematic internal monitoring — not manual checks alone — can reliably manage risk and satisfy compliance requirements.
This shift presents an opportunity to strengthen both internal processes and supply chain collaboration. While additional staff and improved procedures remain valuable, they work best when supported by systematic verification. Retailers who combine strong supplier relationships with scalable compliance tools will be best equipped to meet these new expectations.
The CMA's 2026 guidance reinforces this shift: retailers now need scalable systems to ensure green claims compliance across their entire product range. Those who invest in robust compliance infrastructure early will be well-positioned to communicate sustainability with confidence — while reducing legal exposure and building consumer trust.
BetterChoice: A Solution Built for Fashion's Scale
This is exactly why we built BetterChoice: a platform designed specifically for the realities fashion retailers face.
We automate green claims monitoring across your entire product catalogue. No IT integration required. No months-long implementation. Within hours, we can identify green claims across thousands of products, flag potential compliance risks, highlight missing certification information, and detect the specific issues that require attention under the new regulations.
We've already analysed over 1.5 million products across fashion brands and retailers, capturing claims in product titles, descriptions, material specifications, care instructions, and certification badges. The system works at the speed and scale your business operates — monitoring continuous changes, new product additions, and updated claims in real time.
We work alongside your legal, ESG, and marketing teams to turn compliance into a foundation for confident sustainability communication.
Want to see what greenwashing risks are currently live on your platform? Let's talk about how BetterChoice can give you the systematic monitoring the CMA now expects — in hours, not months.