Regulatory and Litigation Focus on Green Claims Intensifies in the EU and UK

Consumer Awareness and Regulatory Action Increase in the EU and UK

The focus on environmental and sustainability-related claims to consumers is intensifying in both the EU and the UK, with a significant rise in regulatory scrutiny expected in 2026. This year appears to be a crucial one for enforcing laws against greenwashing.

In the EU, the Empowering Consumers for the Green Transition (ECGT) Directive, along with the Commission’s comprehensive November 2025 Questions and Answers, are ushering in much stricter standards for validating environmental claims. Terms such as generic sustainability labels and brand names that suggest environmental benefits without strong evidence are now restricted. Member States have ramped up enforcement efforts, particularly targeting claims related to carbon neutrality, circularity, and sustainability in sectors like aviation, fashion, logistics, and consumer goods.

Similarly, the UK is also tightening its regulations. The Competition and Markets Authority’s guidance on supply chain liability from January 2026 broadens the responsibility of companies for environmental claims originating from upstream suppliers. Moreover, the Advertising Standards Authority is raising the bar with updated guidelines and notable verdicts.

These adjustments underscore a clear direction in regulatory requirements: environmental claims must be specific, verifiable, and backed by reliable evidence. Companies need to enhance their due diligence in the supply chain, substantiation processes, and internal controls to comply with the increasingly stringent rules in both the EU and the UK.

European Union

The scrutiny on greenwashing has been a predominant concern for EU institutions and national authorities in 2025, hinting at heightened vigilance in the year ahead. The looming deadline for Member States to transpose the ECGT Directive by March 27, 2026, fuels this anticipation, with the new regulations taking effect on September 27, 2026.

The European Commission’s release of detailed Questions and Answers in November 2025, tailored to assist companies ahead of national transposition, signals a marked increase in the expectations regulators have regarding the validation and presentation of environmental claims. Concurrently, Member State authorities continue to carry out prominent enforcement actions across various industries. Businesses operating in the EU must promptly bolster governance, conduct lifecycle assessments, and enhance supply chain oversight.

Impending ECGT Directive and Commission’s Questions and Answers Publication

The ECGT Directive brings notable changes to EU consumer protection laws, amending the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive. It specifically targets vague or generic environmental claims and prohibits certain misleading practices related to sustainability. These alterations expand the list of prohibited unfair practices under the UCPD, underscoring the necessity for rigorous substantiation and transparent messaging to prevent misleading consumers about sustainability.

The Commission’s issuance of the Questions and Answers on November 27, 2025, clarifies that these amendments are targeted at fortifying the EU’s horizontal consumer protection framework and do not supersede sector-specific regulations. With the deadline for transposition approaching, businesses must promptly revise their marketing materials to adhere to the new evidence-based standards.

Furthermore, the Commission emphasizes that while corporate sustainability reporting falls outside the scope of the UCPD/ECGT framework, any reuse of such reports in consumer-facing marketing necessitates compliance with the regulations if environmental claims are made or implied. Additionally, claims of a product’s positive or neutral environmental impact should be evaluated considering various factors, including visual cues like imagery and color schemes that may suggest environmental benefits.

In conclusion, the EU and the UK are paving the way for more stringent regulations to combat greenwashing and ensure that environmental claims are truthful, substantiated, and transparent. Companies must adapt swiftly to these changing requirements to regain consumer trust and align with the evolving standards in sustainability marketing.