SUSTAINABILITY / SECTOR LENSES
Retail & Consumer
Green Claims Directive, EUDR, packaging rules, and supply chain traceability. The era of unsubstantiated environmental claims is ending.
In brief
Retailers and consumer goods companies face sustainability scrutiny from three directions simultaneously: regulators cracking down on greenwashing (both UK CMA and EU Green Claims Directive), supply chain deforestation rules (EUDR), and packaging obligations (EPR). The common thread is that sustainability claims now require substantiation — and supply chain sustainability requires traceability. Both demand investment in data, not just in communications.
The Green Claims Directive shifts the burden of proof entirely onto the brand: you must prove the claim before you make it, not defend it after it is challenged. For retailers who have built marketing around generic sustainability language, this requires a substantive audit of what can credibly be said.
The framework landscape
Requires environmental claims to be substantiated by recognised scientific evidence, independently verified before use, and kept up to date. Bans generic claims ("eco-friendly", "sustainable", "natural") without specific substantiation. Proposed adoption 2024; member state transposition by 2026. UK businesses selling into the EU must comply.
Competition and Markets Authority guidance on environmental claims under the Consumer Protection from Unfair Trading Regulations. Not a new law — it applies existing consumer protection law to green claims. The CMA has enforcement powers and has used them. The shift from vague aspiration to specific, substantiated claims is required now, not in 2026.
Retailers selling forest-risk commodities (timber, paper, leather, rubber, palm oil, soy, cocoa, coffee, cattle) into the EU must demonstrate those commodities have not contributed to deforestation or forest degradation after 31 December 2020. Traceability to plot level required. Now postponed to 30 December 2026 for large operators and 30 June 2027 for micro and small operators; coffee and cocoa keep this squarely relevant to consumer-facing retail.
UK packaging EPR launched 2025. Producers, importers, and retailers handling 50+ tonnes of packaging per year face new obligations: registration, data reporting, financial contributions based on packaging type and recyclability. Drives a shift toward lighter, more recyclable, and reusable packaging.
For large retailers operating within the EU or with significant EU revenue. ESRS S1 (own workforce), E1 (climate), E5 (circular economy), and consumer sector-specific standards cover material sustainability topics for retail. Supply chain disclosure (ESRS G1, upstream) is a significant new obligation. The EU Omnibus I package (March 2026) has since narrowed CSRD scope to larger companies, so fewer mid-size retailers fall directly in scope, though supply-chain data requests from larger customers continue to flow down.
The EU Digital Product Passport central registry is due July 2026, attaching verifiable, machine-readable product-level data (composition, durability, recyclability) to goods sold into the EU. It turns substantiated product claims from a marketing choice into infrastructure for anyone selling into the EU.
The UK Circular Economy Growth Plan is expected, and a UK-wide 20p deposit return scheme is confirmed (Wales from 1 October 2027). Combined with packaging EPR, the direction is clear: packaging and end-of-life are becoming priced obligations, not voluntary good practice.
Category 1: purchased goods and services, the embedded carbon in stock sourced from suppliers. The largest emissions category for most retailers by volume. Category 11: use of sold products, for products that generate emissions during use (e.g. appliances, clothing requiring washing). Scope 3 data is increasingly required by investors and increasingly contested by regulators for accuracy.
Where organisations typically start
Retailers with sustainability marketing
A green claims audit is the first step: reviewing all environmental claims across packaging, advertising, and digital channels against the CMA Green Claims Code. Claims that cannot be substantiated need to be removed or qualified before they become an enforcement issue. The UK CMA has enforcement powers and has already used them on major brands.
Retailers with food, timber, leather, or other forest-risk commodities
EUDR commodity mapping identifies which products trigger the regulation and what traceability currently exists in the supply chain. For most retailers, plot-level traceability does not currently exist — building it requires supplier engagement, data systems, and potentially switching to certified sources.
Sub-sector depth
Some industries within Retail & Consumer have a distinctive enough regulatory and MRV profile to warrant deeper treatment than the sector overview provides. These sub-sector pages go into the specific frameworks, certifications, and supply chain challenges that apply to that industry — while the sector page above covers the shared obligations that apply across retail broadly.
Fashion & Apparel
Sub-sectorDigital product passports, fibre traceability, mass-balance limitations, and the MRV gap from cotton farm to finished garment. Where supply chain transparency meets sustainability disclosure.
More sub-sectors being built: Food & Drink, Electronics & Technology. Each will follow the same pattern — deeper treatment of the industry-specific regulatory and supply chain picture that sits beneath the sector overview.