If, like me with Avallen Calvados, you've been making environmental claims on your packaging, website, or social media such as "sustainable," "carbon neutral," "eco-friendly," or "climate positive" and you haven't recently checked whether those claims would stand up to regulatory scrutiny, now is the time to do that.

The UK's anti-greenwashing rules changed substantially in April 2025, and you're absolutely forgiving for not knowing as there hasn't been much noise or announcements about it.

I'm going to try and explain, in plain simple English and as few acronyms as I can realistically manage, what the law now requires, what the consequences of getting it wrong look like, and what you need to do about it.

What Changed in April 2025

The Digital Markets, Competition and Consumers Act aka the DMCC Act (acronym #1 ) came into force in April 2025. For anyone making green claims about their products, this is the most significant shift in UK consumer protection law in years.

Before the DMCC Act, the Competition and Markets Authority aka CMA (#2) had to go to court to enforce against misleading claims. The process was slow, expensive, and really only beneficial for law firms. The DMCC Act changed that completely. The CMA can now investigate, fine, and impose remedies directly, without going anywhere near a courtroom.

The penalties are not trivial. Fines of up to 10% of global annual turnover are threatened, tho I doubt that many fines of that size will be enforced, especially for smaller drinks brands.

The CMA has also been explicit that greenwashing is a priority enforcement area. It estimates that around 40% of online green claims could be misleading and has already pursued formal enforcement actions against ASOS, Boohoo, and George (clothes by Asda) for misleading sustainability claims in fashion.

In January 2026, it issued guidance making clear that liability extends to any company that repeats or relies on a misleading green claim, including suppliers and distributors, not just the brand owner.

The drinks sector hasn't seen a named enforcement case.....yet. (was that dramatic enough for effect?)

The Green Claims Code: What It Actually Requires

The practical compliance framework for UK brands is the CMA's Green Claims Code (GCC for #3). It's been around for a few years, but it has had its gum shield taken out and been given real enforcement teeth from April 2025 onwards.

The Code sets out six principles.

Claims must be truthful and accurate. The environmental benefit you claim must be real and reflect the actual impact of your product. Not the impact you're working towards. Not the impact you'd achieve under ideal conditions. The actual current impact.

Claims must be clear and unambiguous. Language consumers can understand. No jargon that obscures meaning such as 'eco-friendly' (what does that really mean anyway?) and absolutely* no asterisks that qualify a headline claim into irrelevance. *probably

Claims must not omit or hide important information. You can't cherry-pick the positive metrics and ignore the negative ones. If your carbon footprint is improving but your water use is worsening, leading with carbon alone may constitute an incomplete, and therefore misleading claim.

Comparisons must be fair and meaningful. "Lower carbon than our 2019 packaging" is fine if it's true and documented. "Lower carbon than the industry average" requires a defined, current, like-for-like reference point. Vague comparisons fail the test.

Claims must account for the full lifecycle. This is where many drinks brands fall short. A carbon claim that covers only production and ignores supply chain, packaging, distribution, retail, and end of life cannot be presented as a whole-product claim. No more claiming your cradle-to-gate footprint as the total, you have to be clear about what's included and what isn't.

Claims must be substantiated. You must hold credible, up-to-date evidence for every environmental claim you make. "We believe we're sustainable" is not evidence. A LifeCycle Assessment (LCA = #4) conducted to recognised methodology, such as ISO 14044, is.

What This Means in Practice

A few scenarios that are worth thinking about honestly.

You call your product "sustainable" or "eco-friendly" on the label. These are vague generic claims. Under the Code, they're only permissible if you can demonstrate clearly what you mean, with evidence. "Sustainable" without a definition and data to back it up is one of the highest-risk claim types.

Does your packaging uses green imagery such as leaves, earthy tones, recycling motifs etc, that implies environmental benefit? Imagery is not exempt. If the visual design of your label implies environmental virtue that your data doesn't support, that's a claim.

You display a certification logo from a scheme you haven't renewed. If the certification lapsed and the logo is still there, that's a false claim. Straightforwardly.

Your carbon neutrality claim relies on offset purchases. The Code requires clear disclosure of the offset component, the type of offsets, and the emissions reduction work behind them. You can't just claim you planted trees anymore without quantifiable evidence of the emissions offset.

You've never done a formal lifecycle assessment. If your sustainability claims are based on rough estimates, supplier assertions you haven't verified, or general industry norms, you don't have the substantiation the Code requires. This doesn't necessarily mean your claims are wrong. It means you currently can't prove they're right, and under the DMCC Act, you need to be able to.

The Supply Chain Issue

The January 2026 CMA guidance on supply chain liability is worth particular attention for drinks brands.

As you and me know, drinks production involves supply chains that are typically long, complex, and often, international. Your malt from Ukraine, your glass bottles from China, your cork from Portugal, your secondary packaging from Birmingham, your logistics provider from Barking: all of these sit within your Scope 3 emissions footprint, and any of them could be the source of a claim you're inadvertently repeating.

The CMA's position is clear: if you make a claim that relies on supplier data or supplier assertions, and that data turns out to be inaccurate or misleading, you share liability. You can't simply pass the claim upstream. You need to verify the sustainability data in your supply chain, not just accept it.

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What About the EU?

For brands selling into European markets, the picture changed unexpectedly last year.

The proposed EU Green Claims Directive (EGCD #I've lost count), which had been progressing through the EU legislative process and was widely expected to come into force, was withdrawn by the European Commission in June 2025. Political opposition, primarily around compliance costs for micro-enterprises, killed it, which is a good thing in my opinion as small businesses have more than enough administrative and financial hurdles at the moment. (sshhh, no one mention EPR!)

That doesn't mean EU-market brands are in the clear. The Empowering Consumers for the Green Transition Directive (ECGT #this has stopped being funny) entered into force in March 2024, with a transposition deadline that has now passed and an application date of 27 September 2026. The ECGT contains substantive anti-greenwashing rules that are broadly comparable to the UK regime: bans on vague generic claims, requirements for substantiation, restrictions on claims based purely on carbon offsets.

If your products are sold in France, Germany, the Netherlands, or anywhere else in the EU, the ECGT will apply to your green claims from September 2026, regardless of what you're dealing with domestically. The requirements are convergent with UK law, but they are not identical, and if you're operating in both markets you need to assess compliance against both frameworks.

What to Do Now

Start with an honest audit of every environmental claim your brand currently makes. Packaging, website copy, social media bios, email footers, trade materials, retailer-facing documentation. This is often more extensive than brands expect and sustainability language can accumulate across touchpoints over years (I know first hand from Avallen).

For each claim, ask: what does this mean specifically? What evidence do we hold? Has it been independently verified? Does it cover the full lifecycle, or just part of it? When was it last updated?

Claims that survive that process are fine. Claims that don't need to be removed or reworked with proper substantiation behind them before you face a CMA inquiry rather than an internal review.

The second step is building the data infrastructure to substantiate claims properly going forward. That means documented Scope 1, 2, and 3 emissions, an LCA conducted to recognised standards, and a process for keeping that data current as your supply chain evolves.

A Quick Way to Start

I've built a free version of alkatera's Greenwash Guardian directly into the homepage at alkatera.com. You can run your brand's claims through it now and get a report back showing where the compliance gaps are. No sales call required, just enter your details and see where you stand.

If you want to go further, building the full data infrastructure, getting cradle-to-grave verified claims, staying current as regulations evolve, then that's what I built alkatera for.

The drinks industry hasn't had a named CMA enforcement case yet. Being ahead of it, rather than caught by it, is the better position to be in.